The FCA Consumer Duty came into force for new products and services on 31 July 2023, and extended to closed book products on 31 July 2024. The first round of implementation work absorbed substantial compliance resource across retail financial services in the two years leading to the initial go-live date. Policy frameworks were documented, board papers were produced, staff training was completed. That work was necessary. It was also, in many cases, where implementation stopped.
What the FCA has made clear through its supervisory engagement since go-live is that Consumer Duty is a continuous obligation to deliver good outcomes, not a point-in-time documentation exercise. Firms that treated it as a project with a completion date are now encountering a second wave of compliance demands, this time under active scrutiny rather than implementation preparation.
The Four Outcomes Framework: Where Banks Are Falling Short
Consumer Duty is structured around four outcomes: products and services, price and value, consumer understanding, and consumer support. The FCA's supervisory attention since go-live has concentrated on whether firms can evidence that they are delivering good outcomes in each area, not merely that they have policy documents asserting that they intend to do so.
The consumer understanding outcome continues to generate the most supervisory challenge. It requires firms to ensure communications are clear, fair, and not misleading, and that consumers are positioned to make informed decisions. The compliance difficulty is that this is not a static test. Products change, communications change, consumer behaviour changes. A firm that conducted a communications audit in 2023 and has not revisited it since has likely allowed a growing gap between its assessed position and its current one. The FCA's reviews have found this pattern repeatedly.
The price and value outcome has attracted the most active supervisory scrutiny. The FCA expects firms to demonstrate that the price of each product is justified by the value it delivers, including to consumers in different market segments. Legacy pricing structures, loyalty differentials, and tiered pricing arrangements that predate Consumer Duty all require analysis against the value outcome. A price and value assessment completed at go-live without a process to refresh it as pricing evolves is a documentation artefact, not a compliance programme.
Board Reporting: The Persistent Gap
Consumer Duty requires firms to produce an annual board report on the outcomes consumers are experiencing. The FCA has reviewed sample board papers from regulated firms and found that many describe the firm's Consumer Duty framework rather than presenting evidence of what outcomes consumers actually receive.
The FCA's expectations on Consumer Duty board reporting were further clarified through supervisory guidance published in the period since go-live. A board paper that contains only narrative assessment without supporting management information on complaint volumes, outcome testing results, consumer understanding metrics, and product performance data does not meet the obligation. Compliance teams whose board report template was produced in 2023 and has not been reviewed since should check it against the current expectation before the next annual cycle arrives.
The MI problem is structural. Consumer Duty outcomes monitoring requires data from product teams, from customer operations, from pricing functions, and from distribution channels. The compliance team's role is to aggregate and apply regulatory judgement to that data. Where the compliance function lacks access to operational data, or where data is not collected consistently across the organisation, the board report cannot do what the obligation requires. Fixing the board report template is not the same as fixing the underlying data collection.
Closed Book Products: A Different Compliance Challenge
The extension of Consumer Duty to closed book products in July 2024 added a layer of complexity for firms holding legacy product books. Closed book products, by definition, are no longer being sold. Their compliance frameworks were typically designed under the Treating Customers Fairly regime rather than Consumer Duty. The FCA's expectation is not that firms must achieve identical outcomes for closed book customers as for open book customers in all circumstances. It is that firms must identify where Consumer Duty outcomes cannot be achieved, and must take proportionate action.
For some firms, proportionate action has meant reaching out to closed book customers to offer migration to current products. For others, it has meant updating communications materials that had not been reviewed since original product launch. There is no single correct answer. The FCA's supervisory approach has been case-by-case, which reflects the genuine diversity of closed book product types. What is not acceptable is the assumption that closed book products are outside the scope of ongoing Consumer Duty obligations because they are no longer sold.
Monitoring Outcomes vs. Monitoring Policies
The core shift Consumer Duty demands in compliance monitoring is the move from checking whether policies exist to checking whether the outcomes those policies are designed to deliver are actually being delivered. These activities require different data, different analysis, and different reporting structures.
Monitoring policies means confirming that the Consumer Duty framework document is current, board-approved, referenced in internal procedures, and communicated to staff. This is necessary. Monitoring outcomes requires ongoing data: complaint analysis by product and consumer segment, NPS or equivalent consumer satisfaction data, outcome testing results, and pricing analysis against value assessments at regular intervals.
Most compliance teams have been diligent about the policy monitoring dimension. The gap is in the outcomes monitoring dimension, particularly in firms where the data needed to assess outcomes lives in operational systems that compliance does not routinely access. Bridging that gap requires process changes outside the compliance function, and those changes are harder to prioritise than updating a policy document.
Consumer Duty Is Not a Static Regulation
The FCA continues to publish guidance, supervisory statements, and policy updates that refine how the four outcomes apply in specific contexts. Each of these publications potentially requires compliance teams to revisit aspects of their Consumer Duty implementation. An outcome assessment that was accurate at go-live may not be accurate now if the FCA has since clarified its expectations for the relevant product type or distribution channel.
We are not saying that every supervisory letter or occasional guidance note requires a full Consumer Duty review. Many publications restate existing expectations or address specific edge cases that do not affect most firms. The point is that a compliance team that is not tracking FCA Consumer Duty publications will find their implementation drifting from the current regulatory expectation over time, without necessarily realising it until a supervisory enquiry makes the gap visible.
Kalipso monitors FCA publications and tags Consumer Duty-related guidance, supervisory statements, and policy updates specifically. When the FCA adds to or refines its Consumer Duty expectations, the compliance team receives a plain-English briefing describing what changed and what, if anything, the firm should review. That monitoring layer is the practical alternative to relying on someone to check the FCA website regularly and assess the significance of whatever has appeared. See how it works on the product page.
