Consumer Duty: ‘Only six months to go’


Ewen Fleming

Ewen Fleming

London Office Head, and Head of Consulting & Financial Services


By the end of January 2024, Consumer Duty will have been live for six months.  It represents the largest regulatory change for a decade and a clear steer that the financial services industry should improve how it acts in the best interests of customers.

Given such a major change, the implications are continuing to stretch many firms, particularly around customer communications, outcome reporting, and demonstrating fair value. 

The regulator has already acted quickly to announce an action plan for Cash Savings and is starting to make interventions on a range of topics.  We can expect further guidance and potentially action against both firms and accountable individuals.

Yet, despite a sprint to the initial deadline of July 2023, this race is looking more like a marathon as the complexity and extent of the regulation is uncovered by firms and the regulator. 

Six months in from ‘go live’, we now find ourselves with six months to go until the next deadline of 31st July 2024. By then, firms should have reviewed their off-sale product ranges, gathered evidence that the regulation is embedding, established their regular reporting on good customer outcomes, and – crucially – enabled their Board to formally consider how Consumer Duty has been embedded in their organisation.  Firms need clear and compelling evidence that they have fully embraced the new principle, and their culture places the customer at the heart of their strategy.

At Johnston Carmichael, we’ve been privileged to support some of the UK’s best financial services organisations with their journey to meet the new Consumer Duty’s expectations.  We’ve seen the questions, the challenges, and (yes) the opportunities that the new regulations give rise to. 

There is no ‘one size fits all’ approach to implementation and embedding – each firm has interpreted what the Duty means to their organisation and their culture.  There is no ‘silver bullet’ to quickly address every aspect of the rules.  As was no doubt intended, it is a challenging piece of regulation that should make every firm think very carefully about how they operate and whether that stands up to scrutiny by meeting the spirit of the Duty.

Despite the obvious challenges and work involved, good – and sometimes exceptional – practice has emerged that has genuinely raised the standards for retail customers in the FS sector.  Firms who have truly embraced the new Duty recognise this as an opportunity to get closer to their customers and are now driving positive and authentic change.

Sharing Insight and Best Practice

As we take stock of progress to date and face into what is required by the next deadline in July 2024, I am delighted to introduce a dedicated series of thought leadership pieces about Consumer Duty.   Throughout January, our team of experts will share their thoughts about the most important aspects of the regulations.  Amongst other key themes, you can expect to read about customer communications, pricing and fair value, and vulnerability.

Our intent is simple.  We want to inform, to challenge, and to prompt you to think about what Consumer Duty means for you and your customers, and ultimately how to preserve the future of your organisation. 

As the industry conversation continues around the new regulations, please do let me know what you think.

We can help

Over the past 2 years, Johnston Carmichael has supported multiple financial services organisations - covering multiple sub-sectors - with their preparation for and delivery of Consumer Duty.  Our work has included project implementation, complex change delivery, strategy development, change governance, assurance, training, and Board/Exco engagement.  We’ve also enjoyed our close, ongoing links with a range of industry experts, trade associations, and regulatory bodies.

Please get in touch with me if you would like to explore how we could help.  We would be happy to tailor our support to your requirements and budget.


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