At its heart, Consumer Duty is about outcomes. Not policies. Not paperwork. Not process for process’ sake. It challenges firms to demonstrate that customers receive fair value, clear communications, appropriate products, and the support they need throughout their journey. We think those are positive things, for customers, for firms, and for the long-term health of the market.
The introduction of the FCA’s Consumer Duty marked one of the most significant shifts in UK financial services regulation in a generation. Three years after the Duty came into force, it’s worth taking stock of the impact it has had.
For consumers, this means greater clarity about products and pricing; fairer value assessments; products designed for real customer needs; better support, especially for vulnerable customers; and communications that are genuinely understandable.
Consumer Duty introduced a more demanding standard: “firms must act to deliver good outcomes for retail customers”. This moved beyond avoiding harm and towards proactively ensuring value, understanding and ultimately, better service.
At a time when household finances are under increasing pressure, this focus on value and transparency is particularly important.
Trust in financial services has not always been as strong as it could be. Consumer Duty directly addresses this by aligning commercial success with customer benefit. When firms are required to evidence fair value and demonstrate that customers understand what they are buying, it reduces the risk of hidden fees, unsuitable products, or confusing terms. Over time, this helps restore confidence in financial products, whether that’s insurance, credit, savings, or protection. Of course, trust is not built through regulation alone, but clear, consistent standards that help create the conditions for it to grow.
Well-implemented Consumer Duty action does more than protect consumers, it improves the competitive landscape. When firms compete on clarity, value, and customer outcomes rather than complexity or opacity, the market becomes healthier. It encourages innovation that genuinely benefits customers: simpler journeys, clearer comparisons, smarter use of data, and more personalised support.
Perhaps the most powerful aspect of Consumer Duty is cultural. It has required Boards and senior leaders to take more accountability for customer outcomes. This shifts the conversation from “Is this compliant?” to “Is this right for the customer?”. That change in mindset can have a profound impact. We have seen it drive better product governance, more thoughtful communications, and stronger internal challenge. It also ensures that vulnerable customers are considered at every stage.
Ultimately, firms that consistently deliver good outcomes will build deeper loyalty and long-term growth. There’s no doubt in my mind that Consumer Duty has set a higher bar, but rightly so. By putting customer outcomes at the centre of strategy, governance, and operations, it’s creating a more transparent, accountable, and customer-focused financial services ecosystem.
That’s something we’re all happy to commit to.
Whatever your specialist area, wherever you are in your journey, we’d love to hear from you.