Reflections on two years of Consumer Duty

Two years on from the introduction of Consumer Duty, firms have made progress but significant challenges remain. Regulatory attention is increasingly focused on vulnerability, customer support and evidencing good outcomes, requiring firms to strengthen governance, management information and monitoring frameworks to demonstrate that customers are receiving fair value and appropriate support.

What happened?

TCC Group recently featured in Money Marketing with an article by Senior Regulatory Consultant Juana Diaz-Landinez, reflecting on the FCA’s Consumer Duty two years after its implementation. The article highlights that while many firms have made progress embedding Consumer Duty, regulatory expectations remain high. The FCA continues to focus on customer outcomes, particularly around vulnerability, consumer understanding and customer support, with firms expected to demonstrate meaningful action rather than simple compliance.

Why does it matter?

As FCA scrutiny evolves, firms are being challenged to prove that their products, services and support arrangements genuinely deliver good customer outcomes. Recent reviews into vulnerable customers, bereavement journeys and power of attorney processes show regulators are looking closely at how firms support customers in practice. Firms that rely on inflexible processes, weak management information or poor vulnerability identification risk falling short of Consumer Duty expectations and exposing customers to harm.

Supporting sources

  1. Juana Diaz-Landinez: Consumer Duty turns two with big expectations still to meet

Frequently asked questions

What are the FCA's current Consumer Duty priorities?

The FCA is placing greater emphasis on consumer understanding and consumer support outcomes, alongside its ongoing focus on products, services, price and value.

Why is vulnerability still a key focus for firms?

Many firms continue to struggle to identify vulnerable customers and demonstrate that support services effectively meet their needs. The FCA expects firms to remove unnecessary barriers and monitor outcomes more closely.

What should firms do to strengthen Consumer Duty compliance?

Firms should ensure management information is outcome-focused, define what good customer outcomes look like, improve vulnerability identification processes and align customer support arrangements with the needs of their target market.

Reviewed by TCC Group Editorial Team

Ready to strengthen your compliance?

Speak to our experts about your regulatory challenges.