Consumer Duty

The FCA’s Consumer Duty represents a paradigm shift, meaning firms need to go further in delivering a higher standard of customer care and protection, and equip customers to make effective decisions in their interests.

The Consumer Duty introduces a new Consumer Principle, which requires firms to “act to deliver good outcomes for retail customers”.

Underpinned by a set of cross-cutting and detailed outcomes-oriented rules, firms are required to implement the Consumer Duty’s requirements for open product and services by the end of July 2023, and for closed books of business by the end of July 2024.

The wide-ranging rules require firms to review their product suite, communications and end-to-end customer journey, and to consider changes in areas including governance and accountability, MI and reporting, product design, pricing, distribution, servicing and culture - all within a challenging implementation timeframe.

Boards must take full responsibility for delivering Consumer Duty, maintaining effective oversight and challenge, and ensuring good customer outcomes are at the heart of their firms’ strategies, objectives, and culture.

Firms should take a risk-based approach to implementation, targeting complex and risky products that pose the greatest to consumer harm, whilst also ensuring programmes are appropriately resourced and focus is dedicated to the continual monitoring and evidencing of consumer outcomes.

As firms move beyond Day 1 compliance, firms should be looking to build the business case for longer term transformative change and enhance existing capabilities, including using technology to drive greater automation and efficiency. Firms should recognise that embracing the Duty is a unique strategic opportunity to deliver on their vision, purpose and market position, as well as drive long-term value generation for their business.

If you have any follow-up questions, please contact David Kenmir, Andrea Wintermantel, David Croker, Stephen Arnold or your usual PwC contact.