Consumer Duty Recruitment

Consumer Duty Recruitment

The FCA’s Consumer Duty — introduced under PRIN 2A (Principle 12) and in full force since July 2024 — is the most significant regulatory change to affect retail financial services firms in a generation. It requires every FCA-regulated firm that serves retail customers to actively demonstrate that it is delivering good outcomes across four specific areas: products and services; price and value; consumer understanding; and consumer support. The obligation is outcomes-based, not process-based — the FCA does not accept compliance as a matter of policy documentation. It expects firms to evidence that customers are actually receiving good outcomes.

This shift has created a sustained wave of senior hiring at regulated firms. The Director of Consumer Duty, Head of Consumer Duty, Consumer Outcomes Director, and Consumer Duty Lead have become established permanent roles at retail-facing financial services businesses — not temporary implementation appointments, but standing leadership positions responsible for embedding Consumer Duty into the fabric of how the firm operates and demonstrating that compliance to the Board and the FCA on an ongoing basis.

FD Capital recruits Directors of Consumer Duty, Heads of Consumer Duty, and Consumer Outcomes leaders for FCA-regulated firms across all retail financial services sub-sectors. Call 020 3287 9501 or email recruitment@fdcapital.co.uk to discuss a Consumer Duty leadership requirement.

“FD Capital has supported SBS Insurance Services over the past three years through the provision of a Fractional FD/CFO. Their expertise has made a significant difference in professionalising our finance function and delivering accurate, timely management information — exactly what our business needed to grow with confidence.”

— Tracey Rees, COO, SBS Insurance Services Ltd

Consumer Duty: What the Regulation Requires

The Consumer Duty is built around a single overarching principle — Principle 12: a firm must act to deliver good outcomes for retail customers. It applies to every firm in the distribution chain that has a material influence on the retail customer’s outcome, not only the firm with the direct customer relationship. This means manufacturers, distributors, intermediaries, platforms, and end-product providers all have Consumer Duty obligations if retail customers are in scope.

The Duty is operationalised through three cross-cutting rules — act in good faith, avoid foreseeable harm, and enable customers to pursue their financial objectives — and four specific outcome areas:

The four Consumer Duty outcomes

Products and services outcome: Firms must design and distribute products and services that meet the needs of the target market, are fit for purpose, and do not impose unnecessary costs or features that do not serve the customer’s interests. This requires a formal target market assessment for each product and a distribution strategy that ensures the product reaches the right customers through appropriate channels.

Price and value outcome: Firms must be able to demonstrate that the price charged for a product or service is reasonable relative to the overall benefits it delivers to the customer. This does not mean firms must be the cheapest, but they must be able to articulate and evidence the value customers receive. The FCA has been particularly active on this outcome in the insurance sector following its previous work on pricing practices and the treatment of loyal customers.

Consumer understanding outcome: Firms must communicate with retail customers in a way that supports informed decision-making — providing the right information, at the right time, in a format the customer can understand. This includes all communications from pre-sale marketing through to post-sale documents, renewal notices, and ongoing correspondence. Firms must test whether their communications actually support understanding, not merely that they satisfy disclosure requirements.

Consumer support outcome: Firms must provide support to retail customers throughout the product or service lifecycle — including at the point of purchase, during the life of the product, and at the point of exit or claim. Firms must not create barriers to switching, claiming, or complaining, and must ensure that customers in vulnerable circumstances receive appropriate support.

The Annual Consumer Duty Board Report

One of the most significant practical obligations of the Consumer Duty is the requirement for the Board to review and approve an annual Consumer Duty report. This report must assess whether the firm is delivering good outcomes across all four outcome areas, identify any areas where outcomes are falling short, and set out the actions the firm is taking to address them. The Board must satisfy itself that the report provides an accurate picture of the firm’s Consumer Duty performance — it cannot simply ratify management’s assessment without challenge.

The Consumer Duty Director or Head of Consumer Duty is the individual responsible for producing this report. This makes the role highly visible at Board level — the annual report is one of the most scrutinised internal documents in any retail-facing regulated firm, and the quality of the Consumer Duty Director’s analysis and evidence directly reflects on the firm’s regulatory standing. The FCA has explicitly stated that it will use the annual Board report as a supervisory tool — firms may be asked to share their report with the regulator as part of supervisory visits or thematic reviews.

What a Director of Consumer Duty Does: Key Responsibilities

Consumer Duty programme leadership

• Leading the firm’s Consumer Duty programme on an ongoing basis — maintaining the Consumer Duty framework, monitoring outcomes data, and driving continuous improvement across all four outcome areas
• Owning the firm’s Consumer Duty implementation plan and ensuring that any gaps or weaknesses identified in the annual review are addressed through specific, time-bound actions
• Chairing or co-chairing the firm’s Consumer Duty governance forum or steering committee — bringing together representatives from product, distribution, marketing, operations, and compliance to embed Consumer Duty accountability across the business
• Managing the firm’s Consumer Duty gap analysis process — periodically reassessing the firm’s compliance against the FCA’s expectations as the regulator publishes new guidance, good practice findings, and thematic review outcomes

Outcome monitoring and data

• Designing and maintaining the firm’s consumer outcomes monitoring framework — identifying the metrics, data sources, and monitoring processes that give the Board genuine evidence that customers are receiving good outcomes, not merely that processes are being followed
• Overseeing the analysis of customer outcome data across all four outcome areas — including product take-up and retention patterns, complaints analysis, claims acceptance rates, customer satisfaction and outcome surveys, and vulnerable customer identification data
• Identifying early warning signals of potential customer harm from outcomes data and escalating these to the CCO and Board before they crystallise into material issues
• Maintaining the firm’s product value assessments — ensuring they are updated regularly, reflect actual customer outcomes, and provide a genuine analysis of price and value rather than a formulaic exercise

Vulnerable customers

• Overseeing the firm’s approach to identifying and supporting customers in vulnerable circumstances — ensuring that the firm’s definition of vulnerability is appropriate, that staff are trained to identify vulnerability, and that appropriate support mechanisms are in place and actually used
• Monitoring outcomes for vulnerable customer cohorts specifically — ensuring that vulnerability does not correlate with worse outcomes and that any disparities are investigated and addressed
• Engaging with the FCA’s guidance on vulnerable customers, including FG21/1, and ensuring the firm’s approach remains aligned with regulatory expectations as guidance evolves

Communications review and testing

• Overseeing the review and testing of the firm’s customer communications to ensure they meet the consumer understanding outcome — working with marketing, product, and distribution to identify and improve communications that do not genuinely support informed decision-making
• Managing the firm’s programme of consumer research and testing — including customer journey mapping, comprehension testing of key documents, and analysis of customer behaviour at key decision points
• Maintaining oversight of the firm’s financial promotions and marketing materials from a Consumer Duty perspective — working alongside the compliance monitoring team to ensure that the consumer understanding standard is applied consistently

Annual Board report production

• Producing the annual Consumer Duty Board report — synthesising outcomes data, gap analysis, third-party intelligence, complaints analysis, and the firm’s forward Consumer Duty plan into a document that enables the Board to make a genuine assessment of whether the firm is delivering good outcomes
• Presenting the annual Board report to the Board, responding to challenge, and managing the Board’s approval process
• Maintaining supporting documentation and evidence that substantiates the conclusions in the Board report, in the event of an FCA supervisory request

FCA engagement and regulatory change

• Monitoring FCA communications on Consumer Duty — including Dear CEO letters, multi-firm reviews, thematic review publications, and supervisory strategy updates — and ensuring the firm’s approach is updated promptly in response
• Working with the CCO to manage any FCA supervisory engagement specifically related to Consumer Duty, including supervisory visits, information requests, and any voluntary or required disclosure of Consumer Duty concerns
• Engaging with industry bodies and peer networks — including the ABI, Investment Association, and other sector bodies — to stay informed of emerging good practice and share knowledge of Consumer Duty implementation across the sector

Consumer Duty Across Financial Services Sub-Sectors

While the Consumer Duty obligations are consistent in principle across all FCA-regulated retail firms, the practical implementation priorities and the areas of greatest FCA supervisory focus differ significantly by sub-sector. FD Capital understands these sector-specific nuances and recruits Consumer Duty leaders with relevant experience.

Insurance

The FCA’s Consumer Duty work in insurance has been shaped by its earlier interventions on pricing practices — particularly the ban on price walking (charging loyal customers more than new customers) and the product governance requirements under the Insurance Distribution Directive. The price and value outcome is the FCA’s highest supervisory priority in insurance, and Consumer Duty Directors in insurance businesses must be able to conduct and defend rigorous product value assessments across the firm’s entire product range. The FCA’s 2024 multi-firm review of Consumer Duty in the insurance sector found significant variation in the quality of value assessments and outcome monitoring across the market. See our insurance CFO page for the broader insurance leadership context.

Investment management and wealth management

In investment management, Consumer Duty adds a layer of outcomes-based obligation on top of the existing MiFID II suitability and appropriateness requirements. The consumer understanding outcome is particularly demanding for investment firms whose products are inherently complex — the obligation to communicate in a way that genuinely supports informed decision-making requires a fundamental review of how investment risks, costs, and performance are communicated to retail investors. The FCA’s 2024 review of Consumer Duty implementation in investment management found that many firms were still treating Consumer Duty as a compliance exercise rather than a genuine business practice. See our investment management CFO page.

Consumer credit and banking

Lenders and credit providers face Consumer Duty obligations that extend across the credit lifecycle — from responsible lending assessment at origination through to forbearance and collections at the point of financial difficulty. The consumer support outcome has particular relevance for credit firms, requiring that customers in financial difficulty receive appropriate support rather than being managed primarily through automated collections processes. The FCA’s 2024 Dear CEO letter to consumer credit firms specifically highlighted Consumer Duty as a priority supervisory focus for the sector. See our banking CFO page.

Fintech and digital financial services

Fintech businesses face the specific Consumer Duty challenge of scaling compliance obligations at pace while maintaining the speed and agility of their product development. The consumer understanding outcome is particularly demanding for fintechs whose customer journeys are entirely digital — the obligation to test whether digital journeys genuinely support informed decision-making requires capability in UX research and behavioural testing that many compliance teams do not have. The fractional Consumer Duty Director model is common in fintech businesses that need senior Consumer Duty leadership but are not yet at a scale that justifies a full-time appointment. See our fintech CFO page.

The Consumer Duty Director and the CCO: How the Roles Work Together

The Consumer Duty Director is distinct from the Chief Compliance Officer (CCO) but works in close partnership with them. The CCO (SMF16) holds personal regulatory accountability for the firm’s compliance with FCA rules, including Consumer Duty. The Consumer Duty Director leads the programme that delivers that compliance — owning the monitoring framework, the outcomes data, the annual Board report, and the day-to-day Consumer Duty governance.

In practice, the Consumer Duty Director reports to either the CCO or directly to the CEO, depending on the firm’s governance structure and the seniority of the appointment. In larger firms with a dedicated CCO and a large compliance function, the Consumer Duty Director typically sits within the compliance function. In smaller firms, the Consumer Duty Director may be the most senior compliance professional focused specifically on conduct, with the CCO function held by a more generalist executive.

The Consumer Duty Director is typically a Certified Function holder under SMCR rather than an SMF holder — though in some firms the Consumer Duty programme may be allocated within the SMF16 responsibilities. See our CCO recruitment page for the compliance leadership context and our SMCR compliance recruitment page for the broader senior manager function framework.

The Fractional Consumer Duty Director

For smaller FCA-regulated firms — particularly those below £1bn AUM or with limited retail product ranges — a full-time Consumer Duty Director may not be commercially justified. The fractional Consumer Duty Director provides senior Consumer Duty leadership on a part-time or portfolio basis, typically working one to two days per week to maintain the firm’s Consumer Duty programme, oversee the annual Board report production, and act as the firm’s subject matter expert in regulatory engagement.

The fractional model is also increasingly used as a bridge appointment — where a firm needs experienced Consumer Duty leadership immediately to address an FCA concern or prepare for a supervisory visit, while a permanent hire is being recruited. FD Capital can deploy experienced fractional Consumer Duty Directors within days of a requirement being confirmed.

What to Look for When Recruiting a Consumer Duty Director

Practical implementation experience

The most important criterion is direct experience of implementing Consumer Duty at an FCA-regulated firm — not merely advising on it or having managed the pre-implementation gap analysis. The best Consumer Duty Directors have led the firm through implementation, produced the first annual Board report, managed the first FCA engagement on Consumer Duty, and embedded the ongoing programme. Candidates who only have implementation project experience without the ongoing management experience should be assessed carefully on what the programme looks like once the initial implementation is complete.

Outcomes data capability

Consumer Duty compliance is evidenced through data, not documentation. The Consumer Duty Director must be able to design meaningful outcome metrics, source and analyse data from multiple systems, identify genuine customer harm signals within the data, and present data-driven conclusions to the Board. Candidates who approach Consumer Duty primarily as a policy and procedure exercise rather than an outcomes data challenge will struggle to satisfy the FCA’s expectations.

Board-level communication

The annual Consumer Duty Board report is the Consumer Duty Director’s primary deliverable. It must be compelling, evidence-based, and capable of withstanding Board challenge. Candidates must demonstrate genuine Board-facing experience — not simply having attended Board meetings, but having presented on Consumer Duty and managed Board challenge on outcomes findings.

Sector-specific regulatory knowledge

Consumer Duty is applied differently across sub-sectors. A Consumer Duty Director joining an insurance firm needs to understand the FCA’s specific expectations around product value assessments and pricing in insurance — which are substantially different from the Consumer Duty priorities in investment management or consumer credit. FD Capital assesses Consumer Duty candidates specifically against the sector context of the hiring firm.

Consumer Duty Director Salary: UK Benchmarks

Salary ranges reflect the relative newness of the Consumer Duty Director as a standalone permanent role — in 2022 the role barely existed as a dedicated function; by 2025 it is a standard appointment at every significant retail-facing regulated firm. Compensation is expected to continue rising as demand for experienced Consumer Duty leaders outpaces supply of candidates with the full implementation and ongoing management experience the FCA’s expectations require.

Frequently Asked Questions

Does every FCA-regulated firm need a Director of Consumer Duty?

Every FCA-regulated firm with retail customers in scope of Consumer Duty needs someone leading its Consumer Duty programme — but not every firm needs a full-time Director of Consumer Duty as a standalone appointment. In smaller firms, the Consumer Duty programme may be led by the Head of Compliance or a senior compliance manager alongside other responsibilities. In larger firms with significant retail books, a dedicated Director of Consumer Duty is increasingly standard. The FCA’s supervisory focus on Consumer Duty outcomes means that any firm without clear senior ownership of the programme is vulnerable to regulatory scrutiny.

Is the Consumer Duty Director an SMCR Senior Manager?

Not typically. The Consumer Duty Director is most commonly a Certified Function holder under SMCR rather than an SMF holder — the personal regulatory accountability for Consumer Duty compliance sits with the CCO (SMF16) or, in some firms, with the CEO. The Consumer Duty Director leads the programme that discharges that accountability. In some Enhanced firms, the Consumer Duty Director may be more senior and hold or co-hold elements of the SMF16 function, but this is not the norm. See our SMCR compliance recruitment page.

What is the FCA’s current supervisory focus on Consumer Duty?

The FCA’s 2024-2025 supervisory strategy makes clear that Consumer Duty is a top priority. Specific supervisory focus areas include: the quality of annual Consumer Duty Board reports; the robustness of product value assessments, particularly in insurance; the treatment of customers in vulnerable circumstances; and the evidence firms have to demonstrate that customers are actually receiving good outcomes rather than merely that the firm has Consumer Duty policies in place. Firms without a credible ongoing Consumer Duty programme — backed by data, led by experienced professionals, and capable of withstanding Board and FCA challenge — face material regulatory risk.

How does Consumer Duty differ from Treating Customers Fairly?

Treating Customers Fairly (TCF) was the FCA’s previous outcomes-based conduct framework, built around six consumer outcomes. Consumer Duty replaces and significantly extends TCF — it is more specific in its requirements (four defined outcome areas with detailed cross-cutting rules), more demanding in its evidencing standard (firms must evidence outcomes, not merely process compliance), more far-reaching in its distribution chain application (every firm with material influence on retail outcomes is in scope), and more prominent at Board level (the mandatory annual Board report has no direct TCF equivalent). Many Consumer Duty Directors spent their careers in TCF roles and have made the transition to Consumer Duty — but the skills required for Consumer Duty are materially more demanding in terms of data analysis, Board communication, and the complexity of distribution chain assessments.

Can FD Capital supply an interim Consumer Duty Director quickly?

Yes. Consumer Duty interim appointments are one of the fastest-growing categories of urgent compliance recruitment. If your firm has an immediate Consumer Duty leadership gap — following a resignation, a forthcoming FCA supervisory visit, or an identified programme weakness — FD Capital can shortlist experienced interim Consumer Duty Directors within 24 to 48 hours. Call 020 3287 9501 directly for urgent requirements.

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