Consumer Duty

This page contains all the relevant material you may need to prepare for the changes. Don’t hesitate to get in touch if you have any further questions.

The Consumer Duty is a new standard set by the Financial Conduct Authority (FCA). Building on existing standards, it sets out to provide better protection for consumers in the retail financial services market by putting customers’ needs first, and setting higher expectations for the standard of care they receive from providers. It will achieve this by:

1. Requiring firms’ services and products to be fit for purpose and offer fair value
2. Requiring firms to help consumers make effective choices, or act in their interests
3. Supporting improved supervisory processes, allowing firms to focus on preventing harm before it arises, or address it more quickly where it does occur
4. Create a more fair and consumer-focused advice landscape where firms can compete and innovate with good consumer outcomes in mind

The Consumer Duty will apply to new and existing products and services for sale or open to renewal from 31 July 2023. For closed products and services, the deadline is 31 July 2024.

The Consumer Duty is likely to increase pressures on firms that run a centralised investment proposition (CIP) or a centralised retirement proposition (CRP). This is because firms will likely need to provide evidence on an ongoing basis of how their CIP or CRP segments clients to meet their individual needs. One way to reduce this burden is to outsource the responsibility for creating and managing investment portfolios to a DFM.

Firms currently following PROD 3 guidelines may choose whether to follow the rules in PROD or the Consumer Duty products and services outcome. However, failing to comply with PROD would also be taken as failing to comply with the Consumer Duty.