FCA Consumer Duty: Two Years On — What the Regulator Is Finding and What Firms Must Fix

July 2025 marks two years since the FCA's Consumer Duty came into force for open products and services. What began as one of the most significant regulatory reforms in a generation has now matured into a live supervisory framework — and the FCA is actively using it. Annual board reports are in, implementation reviews are underway, and enforcement activity is beginning to take shape.

What the FCA Has Found

The FCA's thematic reviews since Consumer Duty went live have identified persistent weaknesses in how firms evidence good consumer outcomes. Common findings include an over-reliance on process metrics rather than outcome metrics, inadequate monitoring of vulnerable customers, and pricing structures that do not demonstrably deliver fair value. The regulator has been explicit: having a Consumer Duty framework is not enough — firms must prove it works.

The Four Outcomes Under the Microscope

The four Consumer Duty outcomes — products and services, price and value, consumer understanding, and consumer support — are all in scope of supervisory review. The FCA has signalled particular concern around the consumer support outcome, where call waiting times, digital-only service channels, and complaints handling are all being examined. Firms in retail banking, insurance, and investments are under the greatest immediate pressure.

Closed Products: The Next Frontier

Consumer Duty extended to closed products and services in July 2024. Many firms are still working through what this means in practice — particularly for legacy products with large customer bases, complex terms, and limited digital infrastructure. The FCA has made clear that ‘closed’ does not mean exempt: firms must actively assess whether closed product customers are receiving fair outcomes.

How Surety Supports Consumer Duty Compliance

Surety enables financial institutions to structure their Consumer Duty obligations across all four outcomes, assign accountability, track evidence of good outcomes, and generate the board reporting the FCA expects. Our platform supports both open and closed product assessments, with configurable workflows that adapt to your firm's structure and existing compliance framework. Contact us to see Consumer Duty in action within Surety.