During its recent multi-firm review, the FCA urged boards to place the Consumer Duty at the top of their regulatory agenda – re-iterating how, along with senior leadership, they will ultimately bear responsibility for the outcomes achieved for customers.

Ahead of the one-year anniversary of the legislation’s introduction on 31st July 2023, boards should now be preparing for their first Consumer Duty annual assessment – as well as the eventuality that the regulator could come knocking for a progress report in the intervening months.

As TCC’s Regulatory Consultant and Consumer Duty expert, Juana Diaz-Landinez, explains:

“It goes without saying that the Consumer Duty has been the big focus for the regulator this year – and as part of my role, we’ve been supporting businesses in their Consumer Duty journey.

The key areas that firms are working on this year are:

  • the carry-over from the implementation phase,
  • their outcomes monitoring management information (MI)
  • and the upcoming 31st of July deadline for the first annual board report”

Ahead of July, we expect the FCA to carry out a focused review of the quality of firms’ annual assessment preparations, request sight of working papers, MI and board reporting.

It’s likely that some intervention will flow from that if firms aren’t able to provide strong evidence that they really challenge themselves to achieve good customer outcomes.



For this reason, boards and senior leaders shouldn’t fall into the trap of assuming the assessment is simply another ‘box ticking’ exercise.

Instead, it should be viewed as an integral tool in your wider governance strategy – one that’s vital in producing quality products and services, mitigating foreseeable harm and, ultimately, delivering the best possible outcomes for customers.

But despite the annual assessment deadline fast approaching, we’re seeing many firms are still unsure what areas of their customer journey to focus on – or even what a successful board report framework should look like.

That’s why we’re helping firms benchmark their process and highlight any gaps in their thinking:

“At TCC, we’ve been supporting firms with their Consumer Duty journey right back from the initial FCA consultation phase – and so we’ve got experience of some of the common challenges that firms have faced, they continue to face, and areas that need a more focus.”

Our team is ready to discuss some of those common challenges and answer any questions that you may have around any aspect of the Consumer Duty – giving you a flavour of some of the risks and issues that we’re seeing in the market.

Our advice is not to leave your assessment plan to guesswork. Enlisting TCC’s independent specialists provides your firm with expert support on:

  • Reviewing management information that feeds into the assessment process
  • Conducting a ‘dry run’ of the assessment to test whether it meets with the boards needs and FCA’s expectations
  • An implementation audit to review how the Consumer Duty has been integrated
  • Assessing the Consumer Duty Price and (fair) Value outcome



Get in touch to find out how we can help you meet your Consumer Duty goals and discuss your regulatory needs – simply use the form below or book a preliminary meeting to discuss your needs.