Two years have passed since the FCA’s Consumer Duty came into force in July 2023, setting a new benchmark for customer protection across financial services.
The Duty requires firms to deliver good outcomes in four key areas – products and services, price and value, consumer understanding, and consumer support – and to demonstrate that those outcomes are achieved in practice.
The FCA has been clear that implementation was only the start. In speeches, Dear CEO letters, and ongoing thematic reviews, the regulator has underlined that it expects firms to evidence their compliance, address weaknesses proactively, and embed the Duty into day-to-day decision-making.
Last year, Broadstone highlighted the FCA’s thematic review of PROD and fair value in the General Insurance and Pure Protection market. That review identified significant weaknesses in product governance, information sharing, and value assessments – early warning signs of the challenges firms would face under Consumer Duty. Two years on, those themes remain central to the FCA’s expectations.
In this article, we outline where the FCA’s focus now lies, the challenges firms face in meeting expectations, and how Broadstone’s Insurance Regulatory and Risk Advisory team supports firms in delivering Consumer Duty compliance at scale.
The FCA’s current focus
The regulator’s attention has shifted from initial implementation to sustained delivery. Areas under particular scrutiny include:
- Fair value assessments – ensuring assessments are robust, data-driven, and consider the full cost of products and services, including distribution.
- Vulnerable customers – evidencing that firms identify and respond appropriately to customers with additional needs.
- Management information (MI) – providing sufficient granularity to monitor outcomes and identify risks before they cause harm.
- Senior accountability – demonstrating that Consumer Duty is embedded at Board and Senior Management Function (SMF) level, with clear ownership of outcomes.
The FCA has indicated that where firms cannot evidence compliance, it will consider interventions such as remediation, skilled person reviews, or restrictions on product distribution.
The challenges for firms
Meeting Consumer Duty requirements is not just a matter of policy. It involves practical, data-driven challenges:
- Data completeness – historic records may not provide the detail needed for value assessments or customer outcome analysis.
- MI design – firms need to identify the right metrics, refresh them regularly, and use them to drive action.
- Operational change – embedding Duty principles into product governance, distribution arrangements, and customer communications.
- Evidencing compliance – keeping a clear audit trail that shows how decisions link to customer outcomes.
These challenges are magnified for firms with large, complex product sets or legacy systems.
How Broadstone IRR supports firms
Broadstone’s Insurance, Regulatory & Risk (IRR) division combines regulatory expertise with data analytics to help firms evidence Consumer Duty compliance. Our services include:
- Fair value assessment support – reviewing existing methodologies and strengthening MI frameworks.
- Data diagnostics – identifying gaps and inconsistencies that could weaken outcome assessments.
- Customer outcome analysis – applying analytical models to measure whether products deliver value across different customer segments.
- Governance and reporting – developing clear, defensible outputs suitable for FCA review.
- Operational support – helping firms to implement improved governance processes without disrupting day-to-day business.
We also work alongside trusted partners where remediation or customer engagement is required, ensuring firms can deliver end-to-end solutions.
Early action matters
The FCA’s message is clear: Consumer Duty is not a one-off compliance exercise. It is an ongoing regulatory expectation, and firms must be able to evidence outcomes on demand. Early action offers significant benefits:
- Reduced regulatory risk – being able to demonstrate proactive monitoring.
- Operational resilience – embedding Duty processes across product lines.
- Cost efficiency – avoiding the higher expense of reactive remediation.
Stronger trust – showing customers, investors, and regulators a sustained commitment to fair outcomes.
Next steps
Two years on, the Duty is entering a new phase of regulatory enforcement. Firms that can demonstrate effective, data-driven compliance will be well placed to navigate the FCA’s next wave of scrutiny.
Broadstone’s IRR team has deep experience in Consumer Duty reviews, data analysis, and regulatory engagement. We help firms bridge the gap between regulatory requirements and operational delivery – ensuring Consumer Duty is not just a policy, but a practice.
