With their Consumer Duty, the FCA are driving a new consumer principle that requires firms to act to deliver good outcomes for retail customers. Consumer Duty represents a ‘paradigm shift’ by placing an expectation that a firm’s approach is embedded at every stage of the customer journey across both the manufacturing and distribution of products and services.

The rules require firms to consider the needs, characteristics, and objectives of their customers, including those with characteristics of vulnerability. As well as acting to deliver good customer outcomes, firms will need to understand and evidence whether those outcomes are being met. What exactly will this mean for firms as implementation unfolds?