Wednesday, 3 December 2025
Consumer Duty: Finding Opportunity Beyond Compliance
The New Era of Customer-Centric Regulation
Since its introduction in 2023, the Financial Conduct Authority (FCA)’s Consumer Duty regulations have transformed how financial institutions think about customers.
Built around four key pillars products and services, price and value, consumer understanding, and consumer support the Duty ensures that positive consumer outcomes are prioritised at every stage of the journey.
But Consumer Duty represents more than a new set of compliance requirements. It marks a fundamental shift from tick-box compliance to outcomes-based accountability, designed to embed customer-centric thinking into the core of every financial organisation.
For forward-looking businesses, this is not just a regulatory obligation but a strategic opportunity to better understand customers, build lasting trust, and strengthen brand reputation.
Driving Cultural Change
Cultural transformation has been a recurring theme in the Consumer Duty journey.
In its 2024 review, the FCA noted that too many governance reports were produced in isolation by Compliance or Consumer Duty teams, with limited input from senior management. This narrow approach risks reducing the regulations to a process exercise rather than a shared organisational commitment.
Earlier this year, the FCA removed the formal requirement to appoint a Consumer Duty Champion, reinforcing that accountability must be embedded at every level of the business.
The conversation has also evolved. Initially, the focus was on improving customer communications and product clarity. Now, greater attention is being placed on identifying and supporting vulnerable customers, ensuring inclusivity and fairness across all interactions.
Financial institutions must not only spot vulnerability signals but act on them compassionately and effectively. This requires a structured approach spanning identification, support, and technology.
Identification
Data Signals
- Missed or late payments
- Frequent overdraft usage
- Sudden drop in income (e.g., reduced salary credits)
Customer Interaction Cues
- Disclosures during calls (e.g., illness, job loss)
- Language indicating stress or confusion in digital chats
Support Actions
Proactive Outreach
- Trigger alerts for customer service teams when vulnerability indicators appear
- Offer tailored repayment plans or temporary payment holidays
Accessible Communication
- Provide plain‑language explanations of products
- Offer multiple channels (phone, email, chat) for those with accessibility needs
Specialist Teams
- Train staff to handle sensitive conversations empathetically
- Create escalation paths for complex cases (e.g., mental health or bereavement)
Technology Enablement
- Use AI‑driven analytics to flag patterns of vulnerability early
- Integrate CRM notes with compliance dashboards to track interventions
How to strengthen cultural adoption:
- Involve senior leadership directly in Consumer Duty reviews and decisions.
- Embed customer outcome metrics in governance and performance frameworks.
- Encourage cross-department collaboration between Compliance, Risk, and CX teams.
How It’s Going: Early Results and Emerging Challenges
Two years in, Consumer Duty appears to be achieving some of its intended outcomes.
In July 2024, YouGov reported that public perception of banks had improved since the introduction of the Duty, with an 11-point increase in those who believe banks protect customers from harm (rising from 40% to 51%). Similarly, those who feel banks provide information that is easy to understand rose from 44% to 55%.
However, the shift to a culture-based regulatory model has also created new challenges. Broader interpretation of outcomes-based rules can result in complexity and inefficiency or even “gold-plating,” where firms over-engineer controls without improving results.
In a recent episode of the Following the Rules podcast, the FCA’s Charlotte Clark cautioned against over-complication, noting that firms and regulators must work together to simplify expectations.
How to stay aligned with FCA intent:
- Test internal interpretations against FCA guidance regularly.
- Engage openly with the regulator to clarify expectations.
- Use external advisors or consultants to benchmark best practice and provide objective feedback.
Data’s Role in Evidencing Outcomes
At the core of Consumer Duty lies data.
To demonstrate compliance, financial institutions must show that products represent fair value, communications are understandable, and vulnerable customers receive appropriate support.
But beyond compliance, the right data strategy can turn these requirements into an opportunity to improve customer experience, operational transparency, and decision-making.
Talan Data x AI helps organisations transform fragmented datasets into actionable intelligence. Through outcome-focused dashboards, customer metrics, and monitoring frameworks, firms can both meet FCA expectations and uncover opportunities for improvement.
Example:
In a recent engagement, Talan helped a client evaluate whether customer communications genuinely drove engagement or were being overlooked. By analysing all communications, not just marketing, we identified which messages fostered interaction and which needed refinement.
This exercise not only ensured compliance but also provided powerful insights into customer behaviour, informing future strategies for engagement and retention.
How to embed data-led compliance:
- Consolidate and standardise customer data across systems.
- Design dashboards that link customer outcomes to measurable KPIs.
- Build monitoring processes that detect risks early and surface actionable insights.
The Road Ahead: Evolving with Technology
Meeting Consumer Duty expectations is an ongoing journey, not a one-off project. As the FCA continues to refine its guidance, financial institutions must remain flexible, keeping customer outcomes and data transparency at the heart of their operating models.
Looking ahead, technology and AI will play a pivotal role in how firms interpret, monitor, and deliver on Consumer Duty.
While innovation presents new opportunities, it also raises questions around trust, explainability, and fairness. Firms that balance regulatory responsibility with data-driven innovation will be best positioned to turn compliance into a competitive advantage.
How to future-proof your approach:
- Integrate AI responsibly into customer analytics and communication models.
- Maintain clear data lineage and explainability for all automated decisions.
- Continuously review and refine compliance frameworks as regulations evolve.
Conclusion
Consumer Duty is more than a regulatory challenge; it’s an invitation to reimagine how customer value is created, measured, and sustained.
Firms that embrace the Duty as a strategic opportunity will not only stay compliant but also gain deeper customer understanding, stronger trust, and a clearer view of where true value lies.
Key Takeaways (TL;DR):
- The FCA’s Consumer Duty shifts focus from compliance to customer outcomes.
- Firms that embrace cultural change and data-driven strategies gain long-term trust.
- Data is central to evidencing fair value, consumer understanding, and support.
- Organisations that integrate compliance with customer insight will outperform.
- AI and advanced analytics are key enablers of future regulatory success.
