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Consumer Duty: Not once and done

What has happened? 

In November 2023, the FCA reported a speech given by Nisha Arora, its Director of Cross-Cutting Policy and Strategy, at a Deloitte event dealing with Consumer Duty. The speech provided an update on the FCA’s view of the future development of the Duty and how it expects to apply it.

What are the key points of the speech?

The following points were emphasised by Nisha Arora under the heading What comes next for firms? 

  • Three months on from implementation, firms need to go back and review their implementation plans, checking that they have made the changes they set out to make. They must be focused on whether they are delivering the outcomes they set out to achieve for the consumers in their target market, especially for customers with characteristics of vulnerability. 
  • One of the key aspects that firms should now be considering is their annual board report. At least once a year a firm’s board, or equivalent governing body, must review and approve an assessment of whether the firm is delivering good outcomes for its customers. 
  • This assessment will be part of the evidence used to assess a firm’s ongoing FCA compliance with the Duty. Firms will need to be able to provide it, and the management information that sits behind it, on request. Firms’ actions, assessments, testing, and evidence need to be continuous.
  • From 31 July 2024, the Duty will also apply to closed products and services, but there will be differences in how some elements of the Duty will apply.
  • The Duty is now an integral part of the FCA approach and mindset at every stage of the regulatory lifecycle, including authorisations, policy development, supervision, and enforcement.   
  • In the coming months, the FCA will continue to work across all sectors to test firms’ implementation and embedding of the Duty. For example, it has recently concluded a second survey measuring small firms’ embedding of the Duty, with plans for a third survey in the new year.
  • An early area of focus will be to look at firms’ complaints data, identifying firms where the Financial Ombudsman Service upholds high numbers of complaints.

How can we help you with FCA compliance? 

Thistle Initiatives has supported firms for over 10 years as a trusted FCA compliance and regulatory advisor. In addition to assisting you as-and-when, our team of specialists can serve as your right hand in meeting and complying with FCA regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your Consumer Duty arrangements, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to