FCA Consumer Duty Board Report Review and Workplan

Who this blog is for:

Board members, senior executives, Consumer Duty champions, and those leading the implementation, monitoring, and reporting of Duty requirements.

At a glance:

• In December 2024, the FCA published the first annual Consumer Duty Board Report Review and upcoming Consumer Duty priorities for H1 2025. The review covered 180 firms across the retail banking, wholesale, insurance, payments, consumer investments and consumer finance sectors.
• The FCA's analysis of the reports assessed Duty compliance across a range of areas, including governance, culture, Duty outcomes, vulnerability considerations, third-party relationships, data management, closed products, action plans, and concluded with an overall assessment.
• The analysis led to findings in eight areas: clear outcomes focus, data quality, analysis of different customer types, clear processes for report production, culture and business strategy, board challenge, information sharing, and effective action.
• Firms should review the findings and assess the relevance to their own Board report and Duty processes, identifying both good practices and areas for improvement. Specifically, firms should focus on enhancing information exchange within the distribution chain, refining their approach to vulnerable customers, fostering robust board challenge, and ensuring they use high-quality data.
• The FCA’s workplan provides a detailed breakdown of Duty priority areas in specific sectors which firms should use to inform their own priorities. For example, with an FCA review of claims handling scheduled for Q2 2025, insurers should ensure they have sufficient evidence to demonstrate good customer outcomes within this area.
• Our detailed summary and analysis of the Duty Board Report review, as well as insights into Duty priorities, are available in the document below.