Current edition
02 October 2025
On Tuesday 30 September, the Financial Conduct Authority (FCA) published 3 key documents.
Previous editions
27 June 2025
With the summer heatwave well and truly upon us, many firms may be settling into the BAU rhythm of Consumer Duty—but don’t be fooled, the FCA’s focus on the Duty is anything but cooling off.
25 March 2025
The Financial Conduct Authority (FCA) released an Action Plan detailing proposals to review and streamline regulatory expectations in the context of the Consumer Duty.
27 February 2025
Confirmation this morning that the FCA has revised their webpage and also announced in this speech by Nikhil Rathi that, from today (27 February 2025), they are no longer requiring firms to have a Consumer Duty Champion (although firms can retain the role if you wish to).
12 December 2024
On 11 December 2024, the FCA published feedback following its review of the First Annual Board Reports - this is the result of a "targeted and thematic review" of the reports from 180 firms from across the retail banking, wholesale, insurance, payments, consumer investments and consumer finance sectors.
29 October 2024
Welcome to the October edition of Consumer Duty View!
In our September edition, we reported on the key findings from the Thematic Review TR24/2 on Product Oversight and Governance in the insurance sector which the FCA released in August 2024.
See our Insights article on this publication here.
12 September 2024
As mentioned in our Flash View, the FCA announced a new Call for Input on 29 July 2024 in order to identify Handbook rules which could be removed or simplified if they overlap with the Consumer Duty. We are aware that there is a lot of industry discussion ongoing within different sectors, with many firms seeing this as an opportunity to provide feedback on their pain points. We have set out more details on this Call for Input further below, but please reach out to us if you would like to discuss further.
7 August 2024
In light of the introduction of the Consumer Duty, the FCA has released a Call for Input in order to identify rules which could be removed or simplified if they overlap with the Duty. The aim of the FCA here seems to be to (i) reduce costs for firms, (ii) streamline the Rulebook and (iii) move to an outcomes-based approach. They are proposing greater reliance on the Consumer Duty in place of specific rules and guidance.
28 June 2024
Following the vulnerability survey flagged in our May edition (for which responses were due on 14 May and the FCA will share findings by the end of 2024) - the FCA have issued another survey to firms as part of a cross-sector review, this time focusing on levels of customer support provided.
17 May 2024
Yesterday (16 May) the FCA published 6 Dear CEO letters to firms in the sectors of retail banking, asset management, consumer investments, consumer finance, life insurance and all other firms.
9 May 2024
In this edition we cover the FCA’s review of firms’ treatment of vulnerable customers, information exchange across the distribution chain, the FCA’s updated AI strategy and Business Plan showing its supervisory focus and more sector specific updates
5 March 2024
In this edition we cover examples of good practice and areas of improvement identified by the FCA in relation to their early supervisory work in relation to implementation, identified via a new webpage and through the FCA's Autumn survey and a summary of the Asset Manager Portfolio letter which includes Consumer Duty points for managers to consider.
22 January 2024
In this edition we cover the FCA’s recent Consumer Duty Speech on ongoing good practice; FCA Dear CEO Letter to Wealth Management and Stockbroking firms; the Advice Guidance Boundary Review in Discussion Paper 23/5, which sets out proposals to help consumers make informed investment and pension decisions, as well as several other FCA letters and statements; as well as an offer to join our upcoming consumer duty event for NEDs and Consumer Duty Champions.
1 November 2023
We are three months post-implementation of the Consumer Duty. In this edition of Consumer Duty View, we highlight some key "Day 2" action items. These are relevant to firms' ongoing considerations, as we move toward year end - and indeed, into the New Year.
For some firms, work remains on closed book products and services. Moreover, one cannot fail to notice the Duty routinely making headline financial news - notably in the wealth management space - with various articles citing the FCA's alleged interactions with a prominent UK wealth manager. Taking everything in the round, there is a dawning realisation that the Duty's principles/outcomes based construct is far from being a box-ticking compliance exercise - rather, the unfolding post-implementation picture is one of the Duty fast becoming a pervasive, go-to supervisory tool for the FCA.
26 July 2023
We started Consumer Duty View in Q2 2022, with one year to go to implementation... and here we are, a year later, with less than one week to go before the Consumer Duty deadline. How time flies!
As well as the usual FCA and industry updates, in this Consumer Duty View we've also included a go live check list with some final actions points for consideration to assist with what will hopefully be a smooth run up to the implementation deadline and beyond.
6 June 2023
The Final Countdown... With the second implementation milestone having passed, and a 2-month countdown until Duty comes into force, this month's Consumer Duty View brings you the key takeaways from the FCA speech on implementation and FCA findings from a review of fair value frameworks, together with updates on the latest industry body and trade association work (focusing on manufacturer / distributor feedback loop and wholesale market considerations), further details relevant to payments, e-money firms and credit firms, and the latest on the EU Retail Investment Strategy.
10 May 2023
The FCA has today published its findings from its review of firms' approaches to fair value assessments under the Consumer Duty. While the FCA was happy that firms are making significant efforts with their fair value frameworks, the FCA also expressed concern that some elements of the frameworks might not prove as effective in practice as could be hoped.
31 March 2023
In this month's Consumer Duty View we bring you the key points from these FCA updates, the latest industry body updates and some interesting information as to what is happening in this space outside of the UK as consumer protection reform clearly gathers momentum globally.
20 February 2023
There’s been quite a few updates already this year, in this edition of Consumer Duty View we cover the latest Financial Conduct Authority (FCA) updates, what’s happening in the Trade Association space, and our partnership with the Surviving Economic Abuse (SEA) charity, of which Penny Miller is a trustee, and its interaction with the Duty (in particular vulnerability).
23 January 2023
With six months to go before the Consumer Duty comes into force, the FCA has published a review of how firms are planning to implement the Duty. The review contains the key findings, together with examples of good practice, and also examples of where firms may need to improve their implementation approach. The findings are drawn mainly from the FCA’s review of the October 2022 implementation plans from around 60 of the largest firms’ plans, and also draws from FCA discussion with other firms in the course of regular supervisory engagement. We discuss the key takeaways.
December 2022
This edition flags an important development for those involved in the implementation of the Consumer Duty within their organisations. The FCA have issued its standard quarterly consultation paper where they are proposing certain clarificatory amendments to the Consumer Duty. These could have a significant impact on how some firms have scoped products and business line in or out of scope for Consumer Duty purposes and should be considered carefully by CD implementation teams.
July 2022
Welcome to our second edition of Consumer Duty View. The final FCA Policy Statement on the Consumer Duty (PS22/9) and the finalised guidance (FG22/5) have been published. The implementation timeline has been confirmed as being phased with a deadline of 31 July 2023 for all in scope new and existing products and services that are open to sale or renewal and 31 July 2024 for closed products and services.
May 2022
Welcome to our very first edition of Consumer Duty View. The Consumer Duty clock is ticking! But don't panic. Consumer Duty View will keep you up to date with what's happening across the market, industry discussions and what the FCA is saying.
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