On 1 November 2023, the FCA published a speech that was delivered by its Director of Cross Cutting Policy and Strategy, Nisha Arora, at an event on “Consumer Duty – Next steps”.

In her speech, Ms Arora makes the following key remarks:

  • Three months on from the Consumer Duty coming into force, the good practices the FCA has already seen underline the importance of this work. Continuing this momentum will realise more and more benefits to consumers, firms and the UK as a whole.
  • The Consumer Duty is not a “once and done” exercise. Firms need to make sure they are learning and improving continuously and must be able to evidence this in their annual board report.
  • Firms who have not considered how they will monitor outcomes for different groups of consumers, including those in vulnerable circumstances, will need to do more to meet the FCA’s expectations.
  • At least once a year, firms’ boards or equivalent governing bodies must review and approve an assessment of whether the firm is delivering good outcomes for its customers. This is one of the key aspects of the Duty that firms should be considering now.
  • Firms with closed products and services should check they are on track to meet the 31 July 2024 implementation deadline.
  • The Consumer Duty remains a top priority for the FCA. The FCA will continue to work across all sectors to test firms’ implementation and embedding, and will share good practice to support the industry.