The Financial Conduct Authority has refreshed its Consumer Duty priorities as it seeks to rely more heavily on the outcomes-based regime while reducing the need for additional prescriptive rules across financial services.
The regulator updated its Consumer Duty focus areas on 24 September, adding links to completed supervisory work and revising details around projects that have developed since its priorities were first set out.
The Duty remains central to the FCA’s 2025–2030 strategy and requires regulated companies serving retail customers to act to deliver good outcomes across products and services, price and value, consumer understanding, and customer support.
The FCA said effective implementation is important because it intends to use the Duty wherever possible instead of introducing new detailed requirements for individual problems.
That approach puts more responsibility on regulated businesses to demonstrate the result their products and processes create rather than treating compliance as a checklist of prescribed actions.
The regulator’s updated programme spans retail banking, consumer finance, insurance, consumer investments, the wholesale buy-side, and sustainable finance.
Fair value remains a prominent theme. The FCA has completed its market study into pure protection insurance and published work on unit-linked pensions and long-term savings, including the transparency of charges and how businesses assess overall product value.
It has also completed work on premium finance in motor and home insurance and said it will continue monitoring prices. Where companies fail to provide fair value, the regulator says its response can include direct supervisory challenge and, in the most serious cases, enforcement.
In retail banking, the regulator has reviewed fair value in small-business current accounts where the Consumer Duty applies, examining both price and value and customer understanding. Findings have been communicated to the companies involved and shared more widely with other providers.
The SME element is notable because Consumer Duty protections do not apply uniformly to every business customer or wholesale relationship. The FCA has separately been consulting on changes intended to clarify the boundary of the Duty and how it should operate across distribution chains.
That consultation proposed removing business involving non-UK customers from scope in certain circumstances and making it clearer where companies can rely on each other when several regulated businesses contribute to the same product or service.
The wider reform agenda is intended to reduce unnecessary cost and complexity while retaining the higher consumer-protection standard introduced by the Duty.
Consumer understanding is another area of continuing work. In credit cards, the FCA has examined whether customers understand promotional offers and receive information in a sufficiently clear form to make decisions.
The regulator is also considering simplification of consumer-credit financial promotion rules where Consumer Duty requirements already create expectations around clear communications. The work forms part of its attempt to remove overlapping rules without lowering the expected outcome for customers.
Insurance remains under scrutiny following the Which? super-complaint covering home and travel products. The FCA is extending work on whether providers meet the Duty’s consumer-understanding requirement, adding another layer to existing reviews of value and distribution practices.
In consumer investments, supervisory activity includes how wealth managers identify customers with characteristics of vulnerability, fair-value assessments in advice businesses, and the risk of unsuitable advice.
The regulator has also reviewed how trading platforms treat retail investors using complex exchange-traded products and is examining whether peer-to-peer lending customers receive a sufficiently clear picture of likely returns.
Model portfolio services are due to receive further attention, with findings on how providers are implementing the Duty expected in the first quarter of 2027.
The breadth of the programme shows how Consumer Duty is becoming embedded into ordinary supervision rather than remaining a standalone implementation exercise. Product governance papers and policies remain necessary, but the FCA increasingly expects businesses to monitor actual customer outcomes, identify weaknesses, and show how management information leads to changes where consumers receive poor value or inadequate support.
That can require stronger links between compliance, product design, customer service, data, pricing, complaints, and board oversight. A problem identified through complaints or customer behaviour cannot be treated solely as a frontline service issue if it points to a weakness in the product itself.
The FCA has also acknowledged that proportionality matters. Its focus-area document says smaller businesses may adopt different approaches from large institutions where appropriate, provided they can still demonstrate good customer outcomes.
The latest update shows an established regime entering a more mature supervisory phase. Completed projects are feeding into ongoing oversight, overlapping rules are being reviewed, and Consumer Duty is increasingly becoming the framework through which the regulator addresses problems that might previously have generated a new set of detailed requirements.
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