Consumer Duty: The Complete UK Guide

Consumer Duty Implementation Support: Find a Compliance Specialist Who Has Run One Before

The FCA’s Consumer Duty is the most significant piece of UK retail financial services regulation in a decade. Introduced under Policy Statement PS22/9, it established a new Principle 12 of Business — a firm must act to deliver good outcomes for retail customers — supported by three cross-cutting rules and four specific outcomes firms must demonstrably achieve. The Duty came into force on 31 July 2023 for new and existing products and services, and on 31 July 2024 for closed products and services. Every UK firm in the retail distribution chain is within scope, whether it manufactures products, distributes them, or sits somewhere in between.

Every serious UK Chief Compliance Officer, Head of Compliance and Risk and Compliance Director has been working on Consumer Duty for the last two to three years. The initial implementation phase is behind us. What has followed has been harder: evidencing good outcomes on an ongoing basis, producing the annual board report on Consumer Duty, responding to the FCA’s multi-firm reviews, and handling enforcement action where implementation has fallen short. The question has shifted from “what does the Duty require?” to “how do we demonstrate we are delivering it?” And the second question is significantly harder than the first.

This guide sets out what the Consumer Duty is, how it differs from the FCA’s previous retail conduct regulation, what firms are actually required to do, and where the practical difficulties lie. It is written for UK business leaders, compliance professionals and board members who want a substantive understanding — not a summary of the FCA’s summaries. FD Capital recruits the senior compliance specialists who run Consumer Duty implementation and ongoing delivery at UK financial services firms, and this guide reflects the patterns we see across those engagements.

What the Consumer Duty Is — and Why It Differs From What Came Before

The Consumer Duty is the FCA’s principle-based regulation requiring firms to deliver good outcomes for retail customers across the entire customer journey. It replaces a patchwork of product-specific conduct rules with an overarching standard that applies across product types, distribution models and customer interactions. The practical effect is a significant shift in how the regulator assesses conduct: the question is no longer “did the firm follow the rules?” but “did the customer get a good outcome?”

The shift from process to outcomes

UK conduct regulation historically focused on process compliance — did you disclose what needed to be disclosed, did you assess suitability before advising, did you handle complaints within the required timescales. A firm that followed the rules could be confident it was compliant, even if individual customers ended up in poor positions. The Consumer Duty changes this. A firm can comply with every procedural requirement and still breach the Duty if its customers are not achieving good outcomes. The burden of proof has shifted: the firm must now evidence that customers are achieving good outcomes, not merely that the firm followed the right processes.

This is a material change in regulatory philosophy. It places more discretion and more responsibility on firms. It also makes compliance substantially harder — because proving an outcome is good requires data, monitoring and analysis that most firms were not previously required to maintain. Firms that approached Consumer Duty as a procedural update typically struggled at the implementation stage. Firms that approached it as a redesign of how they measure customer outcomes have fared considerably better.

The scale of what was required

At implementation, firms were required to review every retail product and service, assess each against the four outcomes, identify gaps, and remediate them. Larger firms produced hundreds of pages of product review documentation, held dozens of governance meetings, and made material changes to pricing, product design, communications and support. For groups operating multiple brands and products, the implementation workstream commonly ran to hundreds of workdays of specialist compliance, legal and commercial time. The ongoing monitoring requirement — proving outcomes remain good — is, if anything, a larger sustained commitment than the initial implementation.

Principle 12 and the Cross-Cutting Rules

Consumer Duty is built on three layers: Principle 12 at the top, three cross-cutting rules that define what Principle 12 requires in practice, and four outcomes that firms must demonstrably achieve. Understanding the relationship between these layers is essential.

Principle 12 — the new FCA principle

The Consumer Duty added a twelfth Principle of Business to the FCA’s existing eleven: “A firm must act to deliver good outcomes for retail customers.” This is the highest-level statement of what the Duty requires. Every rule and guidance point underneath it is ultimately a specification of what “acting to deliver good outcomes” means in specific contexts.

The three cross-cutting rules

Underneath Principle 12, the cross-cutting rules explain what firms must do to comply. Unlike the outcomes (which focus on specific areas), the cross-cutting rules apply across all firm activities affecting retail customers.

Act in good faith toward retail customers. This is a broad standard requiring honest and fair dealing. It extends beyond avoiding misrepresentation to include proactive honesty — not exploiting customer biases, not designing products or processes that take advantage of behavioural weaknesses, not concealing material information behind dense disclosure documents.
Avoid causing foreseeable harm to retail customers. Firms must actively identify harms that could foreseeably arise from their products, services, communications and processes, and take steps to prevent those harms materialising. This is broader than prohibiting obviously harmful practices — it includes identifying latent risks (e.g. a product that works well for typical customers but harms vulnerable ones), and acting to mitigate them.
Enable and support retail customers to pursue their financial objectives. Firms must not merely avoid harm but must positively support customers in achieving what they are trying to achieve. This shifts the question from “is the customer worse off?” to “did the firm help the customer get where they were trying to go?”

The cross-cutting rules apply to all retail customer interactions. They are not limited to the four outcomes — they set the baseline behaviour the FCA expects at every point in the customer journey.

The Four Outcomes

The Consumer Duty specifies four outcomes that firms must deliver. Each outcome corresponds to a major area of the customer journey, and each has its own detailed rules and guidance. Understanding the four outcomes in depth is essential to understanding what compliance requires in practice.

Outcome 1: Products and services

Products and services must be designed to meet the needs of an identified target market and be distributed accordingly. This requires firms to:

Define a specific target market for each retail product — not just a broad demographic, but the specific needs the product is designed to meet.
Ensure the product features, risks and characteristics align with that target market.
Distribute only to customers within the target market (or with appropriate justification for those outside it).
Review products periodically to ensure they continue to meet target market needs.
Manufacturers and distributors both have responsibilities — the manufacturer must set the target market and communicate it; the distributor must respect it in who they sell to.

This outcome has driven significant product rationalisation at many firms. Products that had accumulated over years, with unclear target markets and overlapping features, have been discontinued, consolidated or redesigned. The discipline of articulating a specific target market has forced firms to make explicit decisions about who each product is for — and, by implication, who it is not for.

Outcome 2: Price and value

Products and services must provide fair value — meaning the price paid by the customer must be reasonable relative to the benefits received. This does not mean cheapest; it means the relationship between price and value must be defensible.

The price and value outcome has proven the most difficult for firms to evidence. It requires:

A formal fair value assessment for each product, documenting the basis on which the price is considered fair.
Consideration of all charges paid by the customer, including ancillary charges, cross-subsidies and non-monetary considerations.
Assessment across the whole distribution chain — a product that represents fair value at manufacturer level can fail the test if distributor commissions push the total cost to the customer beyond fair value.
Comparison against alternative products available in the market where possible.
Specific consideration of vulnerable customers and whether they are paying more or receiving less than other customer groups.

The fair value assessment is now a standard governance document in regulated firms, reviewed by product committees, compliance and ultimately the board. Firms that treated it as a light-touch compliance exercise have repeatedly been challenged by the FCA in supervisory reviews. The expectation is that fair value assessments are substantive, data-driven and refreshed at least annually.

Outcome 3: Consumer understanding

Communications must be clear, fair and not misleading, and must enable customers to make effective decisions. This applies across all customer-facing communications — marketing, sales documentation, terms and conditions, ongoing servicing communications, and correspondence about complaints or detriment.

The consumer understanding outcome has driven a material rewrite of customer communications across UK retail financial services. Firms have:

Simplified key facts documents, product summaries and terms and conditions.
Tested communications with actual customer groups, particularly vulnerable customers, to verify comprehension.
Reviewed the timing of key disclosures to ensure information reaches customers when decisions are actually being made.
Eliminated jargon, small print and design choices that obscured material information.

The test under Consumer Duty is not whether the communication was technically accurate or compliant with specific disclosure rules. The test is whether a reasonable customer, including those with cognitive or circumstantial vulnerabilities, would actually understand what they needed to understand at the point of decision. That is a materially higher standard than traditional disclosure regulation.

Outcome 4: Consumer support

Firms must provide support that meets customers’ needs throughout the product lifecycle — not just at the point of sale. This includes servicing interactions, complaint handling, changes to circumstances (death, illness, financial difficulty), and any situation where the customer needs to act on the product.

Specific requirements include:

Support channels (phone, online, in branch where applicable) that are appropriately accessible and adequately resourced.
Handling of vulnerable customer situations with appropriate care and adjustment.
No unreasonable barriers to taking beneficial actions — switching products, exercising rights, making claims or closing accounts.
Complaint handling that reaches good outcomes, not just meets procedural timescales.

Consumer support is the outcome that has driven the most operational investment. Call centre capacity, online self-service tools, vulnerable customer processes, complaints handling resources — all have been materially expanded at many firms in response to the Duty.

Scope — Who the Duty Applies To

The Consumer Duty applies to all firms carrying out regulated activities where there is a connection with retail customers in the UK. This includes firms that do not deal with retail customers directly, if their activities influence retail customer outcomes. The scope is deliberately broad.

Firms within scope

Manufacturers of retail products — banks, insurers, investment firms, pensions providers, consumer credit firms, mortgage lenders, friendly societies and so on. Any firm that designs a retail financial product is within scope for that product.
Distributors — advisers, brokers, platforms, aggregators, affinity partners. Any firm that places retail products with customers is within scope for its distribution activities.
Intermediate firms — reinsurers, wholesale firms, fund managers whose funds are sold to retail customers via distributors, technology providers supplying retail-facing systems. Even where these firms have no direct contact with retail customers, their decisions affect retail outcomes and they have Duty obligations accordingly.
Appointed representatives — covered through the principal firm’s obligations, with the principal responsible for ensuring the AR network operates consistently with the Duty.

The distribution chain concept

A central concept in Consumer Duty is the distribution chain — the sequence of firms whose activities affect a retail customer outcome, from product manufacturer to point of sale. Every firm in the chain has responsibilities appropriate to its role, and firms must work together to ensure the end-to-end outcome is good. A manufacturer cannot discharge its duty purely by designing a fair product if the distribution arrangements mean the customer pays fees that make the overall outcome unfair. A distributor cannot rely on the manufacturer’s product design if the way it distributes the product creates harm.

Distribution chain obligations include formal information exchanges — manufacturers must provide target market and value information to distributors, distributors must feed back information about how the product is performing in practice. These exchanges are governed by rules on timing, content and record-keeping.

Retail customers

The definition of “retail customer” for Consumer Duty purposes is broad. It includes natural persons using financial services for non-professional purposes, small businesses in some contexts, and other customers treated as retail under FCA rules. Firms must identify which of their customers fall within the retail definition and apply the Duty accordingly. Customer classification is not always straightforward — a small business can be a retail customer for some products and a professional customer for others — and firms have had to build customer classification logic carefully.

Governance: The Consumer Duty Champion, the Board and the Annual Report

The Consumer Duty places explicit governance obligations on senior management. The regulation does not merely require firms to comply — it requires the board to own the compliance.

The Consumer Duty Champion

Firms within scope must appoint a Consumer Duty Champion — a board-level individual with responsibility for ensuring the Duty is considered in board discussions and is treated with appropriate seriousness. The FCA’s expectation is that this role is held by an independent Non-Executive Director, though the regulation permits other arrangements in smaller firms. The Champion is not responsible for implementation themselves — that sits with executive management — but they are responsible for ensuring the board discharges its oversight role.

Board oversight and decision-making

The board of a regulated firm must understand the Duty, receive appropriate management information on outcomes, and make informed decisions on areas where the Duty requires judgment. Boards cannot delegate Consumer Duty oversight to compliance committees or executive management alone. Consumer Duty items should appear on board agendas regularly, not only when specific issues arise.

The annual Consumer Duty board report

Firms must produce an annual board report assessing Consumer Duty compliance and outcomes. The report:

Sets out the firm’s monitoring of customer outcomes across the four outcomes.
Identifies areas where outcomes are not being achieved and remediation plans.
Evidences that the firm is acting in good faith, avoiding foreseeable harm and supporting customers to pursue their objectives.
Is reviewed by the board and signed off before any externally visible statements are made.

The board report is not filed with the FCA but must be available for supervisory review on request. The quality of these reports has become a de facto indicator of Duty maturity — firms with light, qualitative reports have typically faced more supervisory attention than firms with substantive data-driven reports.

For related guidance on governance accountability more broadly, the Senior Managers and Certification Regime provides the broader framework within which Consumer Duty accountabilities sit. Our forthcoming SMCR guide will cover the specific interaction between SMCR senior manager responsibilities and Consumer Duty obligations.

Fair Value Assessments — the Most Difficult Workstream

Across the firms we work with, the fair value assessment has consistently been the hardest Consumer Duty workstream to deliver. This is worth exploring in more depth because it is also the area where firms are most likely to fall short on supervisory review.

What a fair value assessment must cover

A fair value assessment must demonstrate that the price a customer pays is reasonable relative to the benefits they receive. This requires:

All costs paid by the customer: Headline price plus any ancillary charges, early exit fees, optional add-ons, cross-sale commissions, foreign exchange margins, platform fees — everything that reduces the customer’s net benefit.
All benefits received: Product features, guarantees, service levels, access to advice, ancillary benefits like customer support or account management.
Market comparison: Where possible, comparison against similar products available to the same customer segments. This is difficult where direct comparators do not exist and requires judgment about what is a meaningful comparison.
Customer outcomes evidence: Data showing what customers actually experience — how often they make claims, how often they achieve expected returns, how often they exercise features they paid for.
Distribution chain effects: For products sold via intermediaries, analysis of how distribution arrangements affect customer net cost and value.
Vulnerable customer analysis: Specific consideration of whether vulnerable customers are receiving different value from other customers.

Common fair value assessment failings

The most common failings in fair value assessments, as seen in FCA supervisory reviews:

Relying on internal benchmarks that do not test against the external market.
Treating the assessment as one-off rather than ongoing — failing to refresh when pricing, competitive conditions or customer outcomes change materially.
Assessing pricing in isolation from distribution, so missing the impact of intermediary commissions on total customer cost.
Failing to distinguish fair value for different customer cohorts — presenting an aggregate assessment when value varies significantly between customer segments.
Insufficient use of customer outcome data — arguing that pricing is fair on theoretical grounds without evidencing what customers actually experience.
Poor documentation — conclusions stated without the underlying analysis, so a reviewer cannot see how conclusions were reached.

Firms that have refreshed their fair value methodology two or three times post-implementation — responding to FCA feedback, internal audit findings and real-world customer outcome data — typically now have assessments that can withstand supervisory scrutiny. Firms that completed the 2023 assessment and have not meaningfully revisited it are in the higher-risk group.

Foreseeable Harm — the Ongoing Monitoring Question

The requirement to avoid foreseeable harm has shifted from a design question (what could this product do to customers?) to an ongoing monitoring question (what is this product actually doing to customers, and are we responding?). This requires systems and data that most firms have had to build from scratch.

Identifying foreseeable harms

Firms must maintain a register of foreseeable harms associated with each retail product. A foreseeable harm is not a certain outcome — it is a risk that a reasonable firm would identify. Examples include:

Products held by customers who have moved outside the target market since purchase (e.g. savings products held long after the customer’s financial position has changed).
Communications that work well for typical customers but fail for vulnerable customers (e.g. digital-only communications for customers without digital access).
Features that create friction for customers trying to take beneficial action (exit penalties, barriers to switching, claims-handling delays).
Pricing structures that inadvertently penalise certain customer groups (inertia pricing, back-book pricing, dual pricing practices).

Monitoring and responding

Once foreseeable harms are identified, firms must monitor whether they are materialising and respond where they are. This requires management information that most firms were not previously producing — complaint patterns by customer cohort, claims outcome data, switching behaviour, dormant product analysis, vulnerable customer flag analysis, and similar. Building this data infrastructure has been a major investment for many firms, and it is now a standing operational requirement, not a one-off implementation task.

Management Information and Customer Outcomes Monitoring

Running a Consumer Duty programme requires specific management information that many firms previously lacked. The FCA’s expectation is that firms can evidence outcomes with data, not with assertion.

The outcomes monitoring data set

A mature Consumer Duty management information pack typically includes:

Product performance by cohort: How products are performing across customer segments, with specific breakdowns for vulnerable customers.
Complaint analysis: Complaint volumes, root causes, upheld rates and customer outcomes from complaint resolution, analysed by product and customer segment.
Persistence and retention data: Customer retention patterns, early exits, and reasons for customer departure.
Fair value monitoring: Ongoing comparison of realised value (what customers actually receive) against expected value (what the product was designed to deliver).
Vulnerable customer identification: Numbers of customers identified as vulnerable, the triggers used, and the adjustments made.
Communications effectiveness: Testing data on customer understanding, comprehension scores, action rates following communications.
Support access metrics: Call answer rates, online service availability, channel mix, complaint handling times and outcomes.

Connecting MI to action

The MI is a means, not an end. Firms that produce substantial Consumer Duty MI but do not act on it have been criticised as strongly as firms with poor MI. The regulatory expectation is that when MI identifies a problem, management responds — pricing changes, process changes, product changes, vulnerable customer adjustments. The link between MI and action is a specific supervisory focus area.

The Enforcement and Supervisory Landscape

The FCA’s approach to Consumer Duty enforcement and supervision is evolving, and has become a significant part of the regulatory operating environment for UK retail financial services firms.

Multi-firm reviews

The FCA has conducted and continues to conduct multi-firm reviews assessing specific aspects of Consumer Duty implementation across sectors. Reviews have covered price and value, vulnerable customer treatment, consumer support standards in specific product areas, and the quality of fair value assessments. The published findings from these reviews are effectively de facto standards — firms whose practices fall short of the patterns the FCA identifies as best practice face supervisory challenge.

Supervisory interventions

Where firms fall short, FCA interventions have included:

Formal feedback through supervision letters requiring remediation plans.
Section 166 skilled person reviews to assess specific areas in depth (see our forthcoming Section 166 guide for more on this mechanism).
Thematic supervisory visits focused on Consumer Duty delivery.
Enforcement investigation where breaches are material or systemic.

Public statements and speeches

FCA leadership has used speeches and published material to communicate expectations and identify areas of concern. Compliance teams at regulated firms monitor these communications closely, and use them to anticipate supervisory focus. The pattern has been consistent: the FCA expects firms to demonstrate genuine outcome focus, not procedural compliance, and has been willing to challenge firms where it sees evidence of tick-box implementation.

Common Implementation and Ongoing Failings

Across the firms we see, certain patterns of Consumer Duty failing recur. Understanding these failure modes is useful for firms wanting to strengthen their position.

Treating it as a compliance exercise only

The most common root cause of failure is treating Consumer Duty as a compliance project rather than a business transformation. Firms that ran Consumer Duty as a compliance-led initiative, without deep engagement from product, pricing, customer service and data teams, typically produced documentation that satisfied minimum requirements but did not actually change customer outcomes. When the FCA looked beyond the documentation to outcomes, these firms were challenged.

Under-investing in data

Many firms under-estimated the data requirements of ongoing Consumer Duty monitoring. Customer outcome data that was not previously collected, analysed or acted on is now a standing requirement, and firms that did not invest in the data infrastructure struggle to evidence ongoing compliance.

Inadequate distribution chain management

Where products are sold through intermediaries, the distribution chain obligations are often the weakest area. Manufacturers relying on intermediaries they did not adequately oversee, intermediaries treating information from manufacturers as paperwork rather than operational guidance — these are persistent failings.

Shallow fair value methodology

As noted earlier, fair value assessments that do not meet the FCA’s expected depth are a pervasive issue. Firms that completed a light-touch assessment in 2023 and have not significantly upgraded it are at risk.

Board oversight in name only

Where board oversight is formal rather than substantive — papers circulated but not properly considered, Champion role filled but not actively discharged, MI presented without discussion — the governance framework does not function as the FCA expects. Substantive board engagement is a specific supervisory focus.

Ignoring vulnerable customer expectations

The FCA’s expectations around vulnerable customers are substantially higher than they were prior to the Duty. Firms that have not rebuilt their vulnerable customer identification, training and support processes are vulnerable to intervention.

The Specialist Roles Firms Need for Consumer Duty Delivery

Consumer Duty has created demand for specific senior compliance roles that did not exist — or existed in much narrower forms — before the Duty came into force. These are the roles FD Capital most frequently recruits for within Consumer Duty programmes.

Head of Consumer Duty / Consumer Duty Officer

A dedicated senior role, typically reporting to the Chief Compliance Officer or Chief Risk Officer, responsible for Consumer Duty delivery across the firm. Responsibilities include programme governance, coordination with product and commercial teams, preparation of the annual board report, interaction with the FCA on Duty matters, and oversight of the outcomes monitoring framework. In larger firms this role has a supporting team; in smaller firms it may be combined with broader compliance responsibilities.

Consumer Duty analysts and specialists

Supporting the Head of Consumer Duty, analysts handle specific workstreams: fair value assessments, outcomes monitoring data, communications testing, vulnerable customer policy, distribution chain management. These are compliance-qualified professionals with strong analytical skills and usually experience in the specific product sector (insurance, lending, investment, pensions, etc.).

Chief Compliance Officer and Head of Compliance

At the senior level, the Chief Compliance Officer or Head of Compliance carries overall accountability for regulatory compliance including Consumer Duty. The skills profile for these roles has shifted — outcomes-focused thinking, data literacy, and stakeholder management across commercial and operational functions have become as important as traditional regulatory knowledge.

Chief Risk Officer

The Chief Risk Officer often owns the foreseeable harm framework and the integration of Consumer Duty risk into the firm’s overall risk management. In firms where operational risk and conduct risk are combined, CRO oversight of Consumer Duty is typical.

Risk and compliance leadership below board

Deputy Heads, Directors of Conduct, Heads of Customer Outcomes and similar roles have become more prevalent as firms build out the leadership layer between CCO and operational teams. These roles manage specific workstreams and provide the depth that a single CCO could not cover.

Head of Regulatory Reporting

Although primarily focused on prudential reporting, the Head of Regulatory Reporting role increasingly intersects with Consumer Duty where outcomes data has reporting implications. As the FCA’s data requirements evolve, this role will carry more Consumer Duty responsibility in many firms.

How FD Capital Places Consumer Duty and Compliance Specialists

FD Capital operates a specialist FCA-regulated firms recruitment practice, separate from our core finance director and CFO recruitment. Our candidate pool in this space includes Chief Compliance Officers, Chief Risk Officers, Heads of Compliance, Heads of Consumer Duty, MLROs, AMLROs and specialist compliance analysts across the major UK retail financial services sectors.

Engagement models

We place in three main engagement models:

Permanent placements for firms building out their permanent compliance leadership — Chief Compliance Officer, Head of Consumer Duty, Head of Risk and Compliance positions.
Interim and fractional placements for firms needing senior compliance capacity for specific workstreams — Consumer Duty implementation, Section 166 remediation, FCA supervisory responses, board report preparation.
Project-based specialist placements for finite workstreams where firms need specific expertise (fair value methodology, vulnerable customer framework build, distribution chain redesign) without permanent commitment.

Sector coverage

Our specialist candidates span the major UK retail financial services sectors: retail banking, consumer lending, retail investment, life and pensions, general insurance, mortgage lending, asset management (where products reach retail customers), and payment services. Each sector has its own Consumer Duty nuances and candidate specialisation, which we reflect in how we match candidates to briefs.

Adrian’s role

Every senior compliance candidate we introduce has been reviewed by me personally. As a Fellow of the ICAEW with 25 years of chartered accountancy practice, I understand the regulatory landscape UK firms operate within and the specific skill sets that senior compliance roles require. I spend time with each candidate before recommending them, and I only put forward candidates I would hire into my own firm for the equivalent role.

Consumer Duty Is Ongoing, Not One-Off — and the Senior Resource Question Matters

The firms that have handled Consumer Duty well are those that recognised early that compliance was not a 2023 implementation project but a permanent change in how retail financial services regulation works. Firms that resourced the ongoing monitoring, governance and remediation work adequately have maintained good regulatory standing. Firms that resourced the implementation but under-resourced the ongoing operation have had repeated issues.

The senior resource question — who owns Consumer Duty delivery, who reports to the board on it, who is accountable under SMCR — is central to firms’ ability to operate with confidence. Where that role is under-resourced, unclear, or held by someone without the appropriate mandate, the consequences show up eventually in supervisory reviews, enforcement cases, or customer outcomes.

FD Capital can help you find the right Consumer Duty, compliance or risk specialist — fractional, interim or permanent — matched to where your firm is on the Consumer Duty maturity curve and what your specific regulatory and commercial context requires.

A Note from Our Founder — Adrian Lawrence FCA

The conversation I have with compliance-function leaders at FCA-regulated firms most often is about the gap between “we have implemented Consumer Duty” and “we can evidence good outcomes to the satisfaction of the FCA on any given Tuesday.” The gap is often bigger than executives realise. The implementation gave firms a framework, a set of documents and a governance structure. What it did not automatically produce was the ongoing discipline of monitoring outcomes, acting on evidence and refreshing the approach as the regulatory environment develops.

The firms that have closed that gap did it with people, not with process alone. A Head of Consumer Duty who owns the programme, analysts who maintain the monitoring, a Chief Compliance Officer who insists on outcomes evidence, a board that takes the annual report seriously and asks difficult questions. Where the right people are in the right roles, Consumer Duty delivery is manageable. Where the people layer is weak, no amount of process documentation compensates.

At FD Capital we place the senior compliance and risk specialists who make the difference. If you are assessing your Consumer Duty resourcing, preparing for a supervisory review, or simply want a second perspective on what good looks like for a firm of your size and model, I am happy to have a direct conversation. Every mandate I take on is handled personally.

Hire a Consumer Duty or Compliance Specialist Who Has Done This Before

Consumer Duty implementation, ongoing outcomes monitoring, fair value assessments, Section 166 response and Chief Compliance Officer leadership are core senior compliance responsibilities — not one-off projects. FD Capital places Consumer Duty specialists, Chief Compliance Officers, MLROs and compliance analysts at UK FCA-regulated firms, as fractional, interim or permanent appointments depending on your timeline.

Call: 020 3287 9501
Email: recruitment@fdcapital.co.uk

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Consumer Duty: The Complete UK Guide