Insurance Edge: Consumer Duty three years on

TCC Group CEO Joe Norburn comments in Insurance Edge on the progress of the Consumer Duty, highlighting transparency and fair value, while addressing remaining gaps.

What happened?

Three years after its introduction, industry experts in Insurance Edge reviewed the impact of the FCA’s Consumer Duty. TCC Group CEO Joe Norburn highlighted significant progress in transparency, fair value assessments, and vulnerable customer treatment, with customer outcomes now firmly embedded in strategic planning.

However, substantial variation remains; while leaders use data and behavioural insights to prevent customer harm, laggards still treat the Duty primarily as a documentation exercise.

Why does it matter?

The FCA is increasing its oversight, as evidenced by a rise in Consumer Duty investigations and whistleblowing reports. Proactive general insurance firms must move beyond static compliance frameworks to continuously test and evidence that customer outcomes are consistently positive throughout the product life cycle.

Supporting sources

Insurance Edge: Consumer Duty three years on August 6, 2026

Frequently asked questions

What has the Consumer Duty achieved in its first three years?

The Duty has improved transparency regarding fee structures, enhanced the focus on fair value assessments, and embedded customer outcomes into corporate governance across the sector.

Why is the FCA increasing scrutiny of Consumer Duty compliance?

The regulator is targeting firms that treat the Duty as a passive paper-based exercise rather than actively using customer data and insights to identify and prevent consumer harm.

Consumer Duty

General Insurance & ProtectionTCC helps insurers, brokers, MGAs and protection providers evidence fair value, strengthen customer outcomes and identify emerging customer harm. We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle.

Reviewed by Joe Norburn, CEO – TCC Group September 2, 2026

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