" if you can evidence delivery of good advice, you are in a very strong position to show good outcomes "
where complex advice is involved. We have also seen firms leverage technology, for example, using a client portal and walking clients through it during annual reviews.
An age-old problem continues to be record keeping; where process improvements or remedial actions have been identified, it is important that there is an audit trail to show how changes have been implemented, particularly where these happen throughout the year.
What are the Consumer Duty“ must haves”?
Consumer Duty hasn’ t been the easiest piece of regulation for firms to implement, mainly because it isn’ t designed to be“ tick box”. We frequently get asked about the Consumer Duty“ must haves”. These will differ depending upon your firm’ s resources and your activities, but we typically encourage firms to focus on the following core areas:
• Quality of advice – possibly the most crucial of all the metrics, if you can evidence delivery of good advice, you are in a very strong position to show good outcomes.
• Key performance indicators – monitoring areas such as source of business, product spread, agreed risk profiles, and fees can help identify areas for greater scrutiny.
• Training and competence – closely following your firms T & C plan, checking staff remain competent and capable and focusing on good quality CPD will drive up standards.
• Ongoing service – evidence of delivery in line what has been promised and to sufficient quality.
• Complaints – while it is never pleasant to receive an expression of dissatisfaction, the process of investigating and responding should be seen as an opportunity to improve existing services.
• Feedback – both from clients and staff, this can be formal or informal, but it is important that it is recorded, offering valuable insight around service improvements and crucially consumer understanding.
• Vulnerable customers – recognising signs of vulnerability, taking steps to adapt your service where practicable to provide additional support and recording and discussing experiences will enhance your firm and the perception of the sector.
• Communications – check that your communications are compliant and up to date. For example, ensure websites contain up-to-date information, e. g. where an adviser has joined the firm, or by clearly signposting complaints procedures or scam awareness messages.
A common challenge we receive from firms is around the concept proportionality. It is true that the amount of time and resource spent on Consumer Duty monitoring will be relative to the resource within your firm, however one thing that the regulator is always keen to remind us of is that all firms must be able to evidence good outcomes.
Where might the regulator focus its attention in the next 12 months?
We pay close attention to the messages coming from the regulator. Most notably, for firms where investment advice is the core service, we have seen the publication of the s165 adviser survey results and, if any firm that has not yet read these results, we would encourage you to do so as soon as possible. The FCA has always said that, as a data led regulator, the survey was both to inform and to direct its supervisory efforts and follow up work.
August 2026 | 7