Consumer Duty

Welcome to Johnston Carmichael’s dedicated hub on the UK’s FCA Consumer Duty.

Consumer Duty represents the largest regulatory change in a decade, raising the standards for how firms protect their customers.

Embedding the Duty involves wide-ranging cultural change across all aspects of the firm’s products and services, including design, distribution, communications, and support.

Understanding of the Duty is continuing to evolve – what the rules mean to firms in practice, how it should be delivered, and how the FCA will intervene and enforce.

Johnston Carmichael has supported some of the UK’s best financial services organisations as they implement the Consumer Duty. 

Key challenges to firms

Consumer Duty touches on all aspects of a firm’s culture and operations. Our work tells us that the following themes are particularly important in meeting the consumer duty expectations:

Key Consumer Duty deadline dates

October 2022: Boards to agree implementation plans and oversight of delivery.

April 2023: Manufacturers to have shared key information with distributors.

31 July 2023: Firms to implement the new rules for new and existing products or services that are open to sale or renewal.

31 July 2024: Firms to implement the new rules for closed-book products or services. Boards should review and confirm how the Duty has been implemented by their firm.

Beyond July 2024: Consumer Duty is not ‘once and done’ – firms need to continually review and evolve how they meet the needs of customers. This includes ongoing measurement and management of consumer outcomes, with demonstrable action taken. The firm’s position is reviewed at least annually by the Board.

How we can help 

The Financial Services team at Johnston Carmichael is here to support you with this major regulatory change. 

We can tailor our services to meet your needs, including regulatory change execution and assurance, strategy development, programme governance, and oversight. We’re here and ready to help you navigate the change.