What happened?
This article is the first in a series spotlighting the Consumer Duty’s four outcomes: products and services, price and value, consumer understanding and consumer support. Neil Dethick, Associate Director at TCC, considers three important areas of the products and services outcome ahead of the 31 October 2022 deadline.
The first area is understanding the characteristics of the target customer throughout a product’s full lifecycle, including design, approval, marketing and ongoing management, with particular attention to the needs of vulnerable customers.
The second area is integrating consumer feedback into product development, and the third is measuring success through the FCA’s expected use of management information, complaints data and its Financial Lives Survey.
Why does it matter?
Neil Dethick suggests firms test themselves against a simple question: if the FCA asked for a substantial sample of customer journeys to prove the customer’s best interests were kept in mind throughout a product’s life cycle, could the firm quickly and easily evidence this, both before and after sale?
Firms are also expected to have a Consumer Duty champion at board or equivalent level, responsible for ensuring the outcomes are discussed in a meaningful way, and to demonstrate a clear process for gathering and acting on consumer feedback.
Who is affected?
Teams responsible for product design, marketing, target market research and board-level Consumer Duty governance across financial services firms.
Key risks
- Being unable to evidence that customer journeys were designed with the target market’s best interests in mind.
- No clear process for gathering and acting on consumer feedback during product development.
- Absence of a board-level Consumer Duty champion responsible for meaningful discussion of the outcomes.
- Management information that does not allow the firm to track consumer trust, confidence or understanding over time.
Actions to take
- Map the full lifecycle of each product or service and confirm governance and evidence exist at every stage.
- Establish a demonstrable process for gathering and incorporating consumer feedback into product development.
- Confirm a Consumer Duty champion is in place at board or equivalent level.
- Build management information that tracks consumer trust, confidence and understanding, alongside complaints data.
Wider implications
The FCA has confirmed it will take a more assertive, data-led approach to monitoring products and services, drawing on management information, complaints data and its Financial Lives Survey. Firms should expect this data-led scrutiny to continue as the Duty embeds.
Recommendations
Firms should prepare now to answer the customer journey test that Neil Dethick sets out, and ensure a board-level Consumer Duty champion and a working feedback loop are in place ahead of the deadline.
Supporting sources
Frequently asked questions
What is the products and services outcome under the Consumer Duty?
It is one of four Consumer Duty outcomes, requiring firms to evidence that products and services are designed, approved, marketed and managed with the target market’s best interests in mind.
What test does Neil Dethick suggest firms apply?
He suggests firms check whether they could quickly and easily provide a substantial sample of customer journeys proving the customer’s best interests were kept in mind throughout the product’s life cycle.
Do firms need a board-level Consumer Duty champion?
Yes, firms are expected to have a Consumer Duty champion at board or equivalent level responsible for ensuring the outcomes are discussed meaningfully.
How will the FCA measure success under this outcome?
The FCA will monitor products and services consumers use and measure consumer trust and confidence using management information, complaints data and its Financial Lives Survey.
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026
- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- 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.
- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Motor FinanceTCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny.