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Implementing the Consumer Duty for closed products and services by 31 July 2024


The Consumer Duty sets higher standards for retail financial services customers. It is a core part of the FCA’s strategy and gives effect to the cross-party mandate we were given by Parliament through the Financial Services Act 2021. Following publication of the Finalised Guidance in July 2022, the Duty came into force for open products and services in July 2023. We thank firms for the efforts they have put into their embedding work over the past two years. The Duty provides a valuable opportunity to improve confidence in the financial services industry and support innovation, healthy competition and growth. We have seen many firms embrace the shift the Duty brings, driving culture change and delivering good outcomes for consumers.  

We gave firms an additional year to apply the Duty to closed products and services. This extension is designed to help firms with large numbers of closed products manage implementation at the same time as continuing to advance and learn from their work on open products and services. In advance of the rules coming into force for closed products and services on 31 July 2024 we are writing to firms to support them in their final preparations.  

This letter sets out:  

  • application of the Duty to closed products and services;  
  • priority issues that are particularly acute or widespread in closed products and services;  
  • action prompts to ensure firms are prepared for the 31 July 2024 deadline for closed products and services (our website gives examples of good and poor practices for open products and services); and  
  • a reminder, in Annex 1, of the definition of closed products and services and an overview of the rules.  

When the Duty comes into force for closed products and services firms need to make sure, and be able to show us, that they are acting to deliver good customer outcomes. We will be proportionate to the harm – or risk of harm - to consumers, prioritising the most serious breaches and acting swiftly and assertively. We expect firms’ senior management to carefully consider the contents of this letter and take steps to ensure their firm is compliant with the Duty by the deadline. We understand firms in some sectors may have no or very few customers with closed products and services, but we are circulating this letter widely to help firms consider broader distribution chains.