Recently featured in Insurance Edge, industry experts reflected on the impact of the Consumer Duty three years after its introduction. Joe NorburnCEO at TCC Group (TCC, Momenta and Recordsure) highlighted the meaningful improvements made in transparency, fair value assessments and the treatment of vulnerable customers, while noting that customer outcomes are now more firmly embedded in strategic decision-making across many firms. 

However, significant variation remains across the industry. While some organisations are using customer data and behavioural insights to identify harm and improve outcomes, others continue to approach the Consumer Duty primarily as a governance and documentation exercise. The article also noted increasing FCA scrutiny, with more Consumer Duty investigations and a rise in related whistleblowing allegations, reinforcing the regulator’s expectation that firms must now demonstrate tangible customer outcomes rather than simply evidence compliance.