FCA Consumer Duty remains one of the top priorities for the FCA into next year as reconfirmed in its “Strategy 2025-2030” document FCA Strategy 2025-30.
Although the FCA is relying on firms to embed the Duty well so that customers experience good outcomes so that they won’t have to introduce more prescriptive rules, they recognise that some firms have experienced challenges working out how to implement FCA Consumer Duty in a proportionate way for their firm and the activities they undertake. This reflects my own experience of working with firms across different sectors who I believe will welcome the FCA’s intention to simplify their requirements in a number of areas including:
- Giving firms more flexibility so that they can take advantage of technology and tailor their approach to customer’s circumstances, particularly those in vulnerable circumstances.
- Providing more clarity on their priorities and future consultations so that firms can plan better.
- Reducing the time, cost and complexity involved in meeting the FCA’s expectations while still focussing on delivering good customer outcomes.
More specifically, we can expect to see the following from the FCA:
Firm reviews:
Thematic, multi-firm and market-wide work which is relevant to a wide range of firms and will will include:
- Considering how firms are designing products and services to meet customer needs, including those with characteristics of vulnerability.
- Assessing how firms are approaching outcomes monitoring requirements.
- Looking at the design and delivery of firms’ customer journeys to ensure customers’ needs are met, with a particular focus on whether customers experience unnecessary friction or barriers along the customer journey.
- Assessing how firms’ communications are helping consumers make informed decisions.
Vulnerable Customers and data protection requirements:
The FCA is aware that some firms are struggling to adhere to data protection requirements while meeting their obligations relating to vulnerable customers and data sharing. They intend to provide more clarity on this in conjunction with the Information Commissioner’s Office (ICO) during Q1, 2026.
Fair value assessments:
The FCA expects that fair value assessments will be robust, comprehensive and actions will be taken where issues, harms or gaps are identified. However, they are aware that some firms have found fair value assessments challenging. Over the coming year, they plan to focus their attention on the following:
Pure protection insurance market study: The FCA will explore consumers’ engagement with, and understanding of, the pure protection insurance products they are buying, the competitive constraints on insurers and intermediaries and firms’ incentives, behaviours and practices. They intend to publish an interim report and proposed next steps towards the end of this year.
Unit-linked pensions and long-term savings: The FCA will look at the transparency of charges across the value chain and how firms assess overall product value. Findings are expected to be published by the end of this year.
Market study into premium finance: Work to understand whether people who borrow to pay for motor and home insurance are receiving fair, competitive deals is ongoing. Interim findings were published in July 2025.
Other sector specific work:
Other work that the FCA intends to conduct over the coming year includes:
- Compliance of small business banking current accounts with the price and value and customer understanding outcomes.
- Customer’s understanding of the terms and conditions of credit card products and if information is clear enough to help them to make an informed decision particularly in relation to promotional offers.
- In the consumer investment space, they will look at:
- Tackling poor identification of vulnerable clients by wealth managers.
- Expectations for wealth and advice firms when assessing fair value.
- Risks to providing unsuitable advice.
- Assessing whether firms are meeting Consumer Duty expectations for retail customers investing in complex exchange traded products (complex ETPs). The FCA aims to publish findings by early 2026.
- Reviewing firms’ outcomes statements to ensure consumers have a clear understanding of whether peer-to-peer platforms achieve the returns they advertise. The FCA aims to publish their findings towards the end of 2025.
- Looking at how model portfolio services (MPS) firms are implementing the FCA Consumer Duty. They expect to start work in Q4 2025 and publish findings in summer 2026.
Sustainable Finance:
Work has been paused on extending SDR to portfolio management.
How Cosegic can help
If you’re looking to stay ahead of these developments and ensure your firm is prepared, get in touch to discuss how we can support you in embedding the FCA Consumer Duty in a practical, proportionate way.
