Consumer Duty

Consumer Duty sets standards of consumer protection across financial services and requires firms to put their customers’ needs first. It materially raises expectations of firms operating in the retail market on how they engage with their customers. 

The FCA has brought in a new Consumer Principle (Principle 12), requiring firms to ‘act to deliver good outcomes to retail customers’. Firms also have to consider the value their products provide to customers and act to prevent foreseeable harm.

From 31st July 2023, all firms must have reviewed their products and services in line with the expectations of the Duty. This raises the bar on product management, sales and servicing arrangements and makes management accountable for ensuring the Duty is a part of the firm’s organisational strategy and governance.

Our Approach

We work with firms required to implement the Consumer Duty including banks, asset managers, private banks, brokers, insurers and payment services firms. Our approach depends on the activities of the firm, the amount of work required to be completed and the risk of potential harm to customers. Our team has practical experience in the  development and integration of ‘outcomes based’ regulatory frameworks and associated governance. We combine this with our consulting expertise to deliver sustainable solutions.

Our Services

We work with both first and second lines of defence to embed Duty requirements into their systems and controls and align Duty with the firm’s risk and compliance frameworks.

We offer a range of services to help firms implement and embed Consumer Duty including:

Project Management and Oversight

Helping firms evaluate whether their plans cover all of the Duty requirements and/or manage their implementation of the Duty.

Product review

Reviewing and making recommendations on product governance, distribution and servicing.

Systems and Controls Analysis

Supporting firms to ensure their control environments are effective when implementing and integrating Duty expectations.

Data Evaluation

Making sure firms have appropriate data to measure ‘good outcomes’ and ‘prevent foreseeable harm’.

Integration with Governance

Ensuring end-to-end governance frameworks consider the Duty and senior managers discharge their responsibilities.


Providing training to staff and management on the Duty and the implications.