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The FCA highlights focus areas for firms in implementing the Consumer Duty

With only 6 months till the implementation deadline for the Consumer Duty regulation, the Financial Conduct Authority (FCA) has published a review of how firms are planning to implement the Duty.

According to this review, some firms are further behind in their planning for the Consumer Duty and may struggle to effectively meet the rules once they come into force on 31 July 2023.

However, the FCA also stated that they have found that many firms show they understand and embrace the shift to delivering good customer outcomes and have established extensive programmes of work to ensure they comply with it.

Sheldon Mills, Executive Director of Consumers and Competition at the FCA, said:

‘The Consumer Duty will bring about a step change in the way financial services firms treat their customers and we welcome the work firms are doing to implement it. Given the scale of the reform, we recognise that some firms need to make significant changes. For firms which are further behind in making the necessary changes, there is time to put that right and for them to show they are acting in the spirit of the new Duty. 

‘Firms will also see the benefits of the Duty, with increased trust in the sector, more flexibility to innovate and in time fewer rule changes.’ 

Key findings for improvement

Whilst finding examples of good practice in its review, the FCA has also identified ‘areas for improvement’, where firms may need to develop their approach further to ensure they meet expectations under the Duty. The review highlights these improvements under the areas of, Governance; Culture and People; Deliverability; Third Parties; The four outcomes; Data Strategies.


  • Firms need to provide more details of those responsible for taking the lead on the overall implantation programme.
  • Plans need to be carefully considered and scrutinised by the firm’s board and committee before being approved.
  • Firms need to be clear on timings of when progress updates on the implementation programme will be provided to key governance bodies, including the board.
  • Ensure a Consumer Duty board champion is appointed.

Culture and People

  • Firms need ensure they set out detailed plans to show how the Duty will be embedded in their culture and people approach. This includes providing examples of tangible actions the firm needs to take.


  • Firms need carry out a gap analysis and ensure project requirements are fully scoped with clear timelines identified.
  • Prioritise rectifying any gaps that have the potential for poor consumer outcomes.
  • Firms need to clearly document any risks related to internal and external dependencies.

Third parties

  • Firms need to specifically identify their key third party relationships and the nature of their dependency with them. They should also ensure that any exchanging of information with third parties is done effectively and in a timely way.

The four outcomes

  • Firms need to show their understanding of the Duty’s requirements and consider the challenges of how they will apply them to their businesses, and the consumer outcomes they are aiming to achieve.
  • Firms should have a clear methodology or approach they intend to use in reviews of gap analyses of products, services, communications and customer journeys against the Duty outcomes.

Data strategies

  • Firms need to identify the data they require to monitor compliance with the Duty, and consider how they will source, package, monitor, govern and act upon the outputs of this data.
  • Consideration needs to be given as to how a firm will monitor outcomes for different groups of customers, including those in vulnerable circumstances.

Focus areas for your Consumer Duty planning

It is important that firms effectively use the next 6 months to ensure they meet the FCA’s requirements by the deadline. To help in their planning, the FCA has asked firms to particularly focus on the following in their review:

  • Prioritising: Firms should make sure they are prioritising effectively, with a focus on the areas that will make the biggest impact on outcomes for consumers. Focusing on reducing the risk of poor consumer outcomes and assessing where they are likely to be furthest away from the requirements of the Duty.
  • Making the changes needed: The FCA urges firms to ensure they are making the changes needed so consumers receive communications they can understand, products and services that meet their needs and offer fair value, and they get the customer support they need, when they need it.
  • Working with other firms: Firms need to share information and work closely with their commercial partners to make sure they are all delivering good customer outcomes. The FCA has found that some firms need to accelerate this work to implement the Duty on time.

For more information

Don’t fall behind in your planning for the Duty. For everything you need to know about the Duty and the requirements for your business, check out our dedicated FCA Consumer Duty section for the latest updates.

If you’d like to know more about how we can assist you with implementation of the Consumer Duty or how we can support you with authorisation arrangements, or any other regulatory compliance matters, please contact our specialist team here.

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