How do we know if our Consumer Duty framework is actually compliant?

Most firms have something in place, but the issue is whether it stands up to FCA scrutiny. The FCA is less interested in whether a framework exists, and more focused on whether you can demonstrate, through evidence, MI and governance, that good customer outcomes are being delivered in practice.

What does the FCA expect to see when they review Consumer Duty?

The FCA typically focuses on: Evidence of outcomes monitoring Quality of management information (MI) Fair value assessments Board oversight and challenge How issues are identified and addressed Firms need to be able to explain not just what they have in place, but how it works in practice and what actions have been taken.

What are the most common gaps firms have under Consumer Duty?

Common issues include: Weak or unclear management information Poorly evidenced fair value assessments Limited outcomes testing Over-reliance on assumptions rather than data Lack of meaningful Board engagement

What should a good Consumer Duty Board Report look like?

A Board Report should provide meaningful oversight, not just a summary. It should clearly show: What outcomes are being delivered Where there are risks of customer harm What management information supports this What actions have been taken or are planned It should allow the Board to challenge and make informed decisions.

How detailed do fair value assessments need to be?

Fair value assessments are a key FCA focus and are often too high-level. Firms are expected to: Assess the total price paid by customers Compare costs and benefits Consider distribution and remuneration Identify whether any customer groups receive poor value They need to be clearly documented and supported by evidence.

We are a distributor - what are we responsible for under Consumer Duty?

Distributors still have significant responsibilities. This includes: Understanding the target market Assessing whether products are appropriate for your customers Monitoring outcomes within your distribution Escalating issues where necessary Responsibilities depend on your role, but cannot be delegated entirely.

Consumer Duty Support

The Consumer Duty raises the standard for how firms treat retail customers. It requires firms not just to comply with rules, but to demonstrate, through evidence, that their products, services and communications deliver good customer outcomes in practice.

We provide specialist Consumer Duty support to help FCA-regulated firms implement, evidence and maintain compliance with the FCA’s outcomes-focused requirements and aligned with how the business actually operates.

We also support firms as part of the FCA authorisation process, ensuring Consumer Duty is properly reflected in business plans, governance arrangements and product design from the outset, as well as supporting firms on an ongoing basis once authorised.

Our focus is on helping firms move beyond high-level frameworks to clearly demonstrate how Consumer Duty is applied across their business, including governance, decision-making and day-to-day operations.

Contact us to discuss your compliance requirements and how we can support your firm.

CONTACT US

Implementing the Consumer Duty Framework

Consumer Duty is not a single policy or document. It needs to be built into how the business operates across the full customer lifecycle.

We work with firms to design and implement Consumer Duty frameworks that are workable in practice and aligned with FCA expectations.

This typically includes:

Mapping products and services to clearly defined target markets
Applying the Consumer Principle and cross-cutting rules in a practical way
Aligning governance, oversight and accountability
Establishing documentation and audit trails that reflect how decisions are actually made

Our approach ensures Consumer Duty is not treated as a standalone compliance exercise, but as part of your firm’s wider systems and controls.

This includes supporting firms preparing for FCA authorisation, where Consumer Duty must be clearly evidenced from the outset, as well as working with established firms to refine and strengthen existing arrangements as the business develops.

Applying the Four Consumer Duty Outcomes

The Consumer Duty is built around four key outcomes. The challenge for most firms is not understanding them, but applying them in a way that can be evidenced and explained.

We support firms in translating the four outcomes into practical processes and controls:

Product and Services

Defining target markets and distribution strategies
Reviewing how products are designed and approved
Assessing whether products continue to meet customer needs over time

Price and Value

Conducting and challenging fair value assessments
Assessing total cost across the distribution chain
Identifying potential areas of poor value or customer harm

Consumer Understanding

Reviewing financial promotions and customer communications
Testing whether customers can make informed decisions
Identifying where communications may be unclear or misunderstood

Consumer Support

Assessing customer journeys and support processes
Reviewing barriers to access, switching or cancellation
Ensuring customers can realise the intended benefits of products

Consumer Duty Support: Monitoring, Fair Value Review & Ongoing Support

A key challenge under Consumer Duty is not just having a framework in place, but being able to demonstrate, with evidence, that it is working in practice.

We work with firms to build and maintain practical Consumer Duty oversight, focusing on how outcomes are assessed, challenged and reported across the business.

This typically includes:

Identifying what management information is useful, and where it is currently missing or unreliable
Designing outcome testing that reflects how your products and customers behave in reality
Reviewing customer journeys, complaints data and product performance to identify where outcomes may not be as intended
Supporting and challenging fair value assessments, including pricing structures, remuneration and distribution arrangements
Reviewing how product governance operates in practice, rather than how it is documented
Identifying areas where assumptions are being relied on instead of evidence
Documenting findings in a way that can be clearly explained to senior management and the FCA
Preparing firms for FCA engagement, including being able to explain and evidence decisions made

We also carry out independent reviews where firms want an objective view of their Consumer Duty arrangements. This is often focused on areas such as fair value, outcomes monitoring, governance or Board reporting, with clear, prioritised recommendations on where improvements are needed.

Our ongoing support is designed to help firms move beyond “having Consumer Duty in place” to being able to demonstrate, with confidence, how customer outcomes are assessed, challenged and improved over time.

Consumer Duty Board Report Support

The FCA places significant emphasis on senior management and Board accountability under Consumer Duty.

We support firms in developing structured Consumer Duty Board Reports, which is an annual requirement, that provide clear oversight of outcomes, including:

Management information and outcome metrics
Fair value and product review findings
Customer behaviour and complaints analysis
Identification of risks of harm
Actions taken and ongoing remediation

We also support firms in aligning Consumer Duty with governance arrangements and senior management responsibilities, ensuring accountability is clearly defined and evidenced.

Consumer Duty Support Across the Distribution Chain

Consumer Duty does not just apply to firms with a direct customer relationship. It applies across the entire distribution chain, and firms are expected to understand how their role influences customer outcomes.

In practice, many firms are unclear on where their responsibilities begin and end — particularly where products, pricing or communications involve multiple parties.

We work with firms to clarify their position within the distribution chain and ensure responsibilities are clearly understood and appropriately managed.

This includes:

Defining your role and level of responsibility within the distribution model
Reviewing how products are distributed and where key decisions are made
Identifying gaps or overlaps in responsibilities between firms
Supporting information sharing between manufacturers and distributors
Assessing third-party relationships, oversight and reliance on other firms
Identifying risks arising from distribution arrangements, including potential customer harm

Our focus is on helping firms move beyond assumptions and clearly demonstrate how their role within the distribution chain is understood, controlled and evidenced.

Support for New and Established Firms with Consumer Duty

We provide Consumer Duty support to a wide range of FCA-regulated firms, including:

Consumer and wholesale investment firms, including advisers and asset managers
Insurance firms, including insurance brokers and managing general agents (MGAs)
Payments and e-money firms
Consumer credit firms
Cryptoasset firms
Fintech firms and startups

Our focus is on how Consumer Duty applies in practice to your business model, products and customer base.

Whether you are preparing for FCA authorisation, implementing Consumer Duty for the first time, or strengthening your existing arrangements, we provide practical support tailored to your firm’s structure, distribution model and level of complexity.