Consumer Duty: from frameworks to outcomes – 12 priority focus areas for regulated firms

Firms often report high confidence in compliance and leadership buy-in, yet consumer evidence of "best interests", value and trust remains materially weaker. The FCA's supervisory question is increasingly: what has tangibly changed for customers? Firms should reframe Duty attestations around customer experience and outcomes rather than programme activity, and triangulate internal MI with external indicators such as consumer feedback and distributor intelligence.

The FCA is using annual board reports as a primary lens on embeddedness and governance credibility, and common weaknesses include insufficient data quality, limited distribution chain analysis, poor cohort and vulnerability analysis, weak evidence of challenge, and action plans lacking owners, timelines and metrics.  Firms should redesign board reports to evidence challenge, decisions and outcome movement, and add an actions tracker with named owners, dates and measurable success criteria.

Consumer Duty is an evidence-based regime, and the FCA is challenging firms where MI is lagging, retrospective, overly reliant on complaints or NPS, or where conclusions are not supported by data.  Firms need to define good outcome statements per product and journey, introduce leading indicators such as drop-off rates, journey completion and error rates, and build root cause remediation and re-test loops with clear escalation triggers.

The FCA has highlighted board conclusions undermined by poor data quality, aggregated reporting and lack of decision-relevant insight. Firms need MI that is disaggregated and able to explain why outcomes are good or poor.  Moving from product-level dashboards to journey-level MI, implementing cohort segmentation across vulnerability, capability, tenure, channel and geography, and establishing clear data ownership and definitions are all essential steps.

Vulnerability is where the "framework vs outcomes" gap is most acute. Reported vulnerability rates vary widely, suggesting inconsistent identification, and many customers needing adjustments are not receiving or using them.  Firms should standardise their identification methodology, track reasonable adjustments end-to-end from offer rate through to effectiveness, and use journey metrics and targeted call listening to evidence outcome improvement for vulnerable cohorts.

The Duty shifts the test from "clear communications" to whether customers actually understand, and the FCA expects testing to be ongoing and representative, not a one-off exercise.  Firms should create a risk-based inventory of communications, prioritise high impact materials for testing, use representative samples including lower-capability customers, and build "test–improve–re-test" cycles with documented evidence of improved comprehension.

Customer support remains a weak driver of trust and sentiment – digital expansion can disadvantage some customers, and poor understanding often increases reliance on support channels.  Firms should map and measure support journey friction including wait times, transfers and abandonment, test parity between entry and exit channels, and ensure support design works for vulnerable customers through accessibility and alternative channels.

Fair value frameworks are largely established, but the FCA continues to test whether firms can evidence impact by cohort and show timely remediation where poor value is identified.  Firms should strengthen fair value MI by cohort and channel, set leading indicators of value deterioration such as cost-to-serve versus fees and persistency rates, and ensure remediation is owned, time-bound and measurable.

The Duty reinforces that firms remain responsible for outcomes regardless of who delivers the service, and weak visibility and escalation across third parties can undermine governance credibility.  Firms should define and contract for outcomes-focused MI with distributors and outsourcers rather than relying solely on service level agreements, and document how issues are detected, challenged and resolved across the chain.

Removal of the mandatory Duty Champion does not reduce expectations. What matters is visible senior ownership, and as Duty supervision and SM&CR converge, accountability risks increase where ownership is unclear.  Firms should refresh Statements of Responsibilities to reflect outcomes accountability, embed outcomes into objectives and scorecards for relevant roles, and consider independent assurance where credibility gaps remain.

The FCA is clear that operational resilience and Consumer Duty are interdependent. This will come to the fore with new operational incident reporting starting on 18 March 2027. Disruption is assessed through the lens of customer experience, especially for vulnerable customers.  Firms should integrate reporting across important business services and Duty outcomes, stress test key customer journeys during disruption scenarios, and use incidents and near-misses to drive remediation and board learning.

Technology is increasingly central to identifying and evidencing outcomes, but it adds value only where governance and journey design are mature enough to act on the insight generated.  Firms should prioritise technology that strengthens single customer view, journey analytics and vulnerability detection, build robust governance for model risk and explainability, and ensure there is a clear audit trail from insight through to action and improved outcomes.