FCA Consumer Duty: Eighteen Months On

Consumer Duty has moved from an implementation exercise to a supervisory baseline. Firms are now being assessed less on whether the required outputs exist — fair value assessments, customer outcome monitoring — and more on whether those outputs are genuinely driving decisions, rather than sitting alongside them unused.

We're seeing this distinction surface directly in supervisory conversations: firms that can show a specific product or process decision that changed because of Consumer Duty monitoring are being read very differently from firms that can only describe the monitoring framework itself.

Our advice to clients at this stage is to audit for exactly this gap — pick a sample of Consumer Duty outputs and ask, specifically, what decision each one changed. If the answer is none, the framework is documentation, not governance, and that distinction is increasingly what supervisors are testing for.

This briefing reflects Alden Advisory's general commentary on a developing regulatory topic and is not legal or regulatory advice. Firms should seek specific guidance for their own circumstances.