Consumer Duty 2025: Raising the Bar for Customer Outcomes

The Evolution of Consumer Duty Requirements

The Financial Conduct Authority (FCA) is set to elevate compliance standards in July 2025, marking a significant evolution from the initial July 2024 implementation. This next phase represents a crucial shift as the regulator moves from theoretical frameworks to evidence-based benchmarks of 'what good looks like.'

Key Changes for 2025

Comprehensive Implementation

The initial phase of Consumer Duty allowed organisations to focus on priority products and services. However, 2025 brings a requirement for demonstrable implementation across entire product and service portfolios. Organisations must now show:

• Complete product lifecycle oversight

• Comprehensive service monitoring

• End-to-end customer journey assessment

Enhanced Reporting Requirements

The FCA expects robust evidence of both risk management and customer outcomes. Organisations need to develop:

• Detailed reporting frameworks

• Clear outcome metrics

• Comprehensive monitoring systems

Value and Pricing Transparency

Organisations must now demonstrate:

• Fair pricing across all products

• Clear value propositions

• Evidence-based pricing decisions

• Regular value assessments

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Meeting the FCA's Evolving Expectations

Evidence-Based Compliance

The 2025 requirements emphasise the need for concrete evidence rather than theoretical frameworks. Organisations must show:

• Quantifiable customer outcomes

• Documented decision-making processes

• Clear audit trails

Practical Implementation Steps

1. Review current Consumer Duty frameworks

2. Identify gaps in implementation

3. Develop enhanced monitoring systems

4. Establish clear metrics for success

5. Create comprehensive reporting structures

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Looking Ahead

As the FCA's expectations continue to evolve, organisations need to stay ahead of requirements through:

• Regular framework assessments

• Proactive compliance measures

• Continuous improvement processes