Consumer Duty
Practical Consumer Duty support across the four outcomes, fair value assessment, outcome monitoring and the annual board assessment for FCA-regulated firms.
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What we do
Consumer Duty is not a documentation exercise. PRIN 2A requires firms to act to deliver good outcomes for retail customers, and the FCA assesses firms on the evidence that outcomes are actually being delivered rather than on the quality of the policy that says they should be.
Most firms completed an implementation project. Far fewer can demonstrate, on demand, that their products represent fair value, that communications are understood, that support is accessible at the point of need and that outcome monitoring is granular enough to expose differences between customer groups.
We work with boards and compliance teams to close that gap. That means testing outcomes rather than processes, building management information that supports a defensible board assessment, and remediating where monitoring shows customers are not receiving the outcomes the firm believes it is delivering.
Gap Assessment
We assess current arrangements against the cross-cutting rules and the four outcomes, focused on evidence rather than documentation.
Outcome Testing
We test real customer journeys, files and communications to establish what customers actually experience.
Evidence & MI Design
We design fair value methodology and management information that a board can use to reach a defensible conclusion.
Board Assessment & Remediation
We support the annual assessment and oversee remediation where outcomes fall short.
What's Included
Consumer Duty Gap Assessment
A prioritised assessment against PRIN 2A, the cross-cutting rules and the four outcomes.
Fair Value Assessment Methodology
A repeatable methodology covering price, benefits, distribution chain costs and differential outcomes.
Outcome Testing Programme
Risk-based testing of files, journeys and communications with calibrated scoring.
Management Information Framework
Outcome-focused MI with thresholds, escalation triggers and board-level reporting.
Annual Board Assessment Support
Structure, evidence pack and challenge to support the board assessment and its conclusions.
Remediation Plan
Practical, sequenced actions where monitoring identifies poor outcomes, with follow-up testing.
Who this service is for
Firm types
- - Insurance intermediaries, MGAs and brokers
- - Mortgage brokers, lenders and networks
- - Consumer credit lenders, brokers and collectors
- - Investment, advice and wealth businesses
Situations & Triggers
- - Board assessment evidence would not withstand FCA challenge
- - Fair value assessments rely on assertion rather than analysis
- - Outcome monitoring cannot show differences between customer groups
- - A supervisory request has exposed gaps in the Duty framework
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
Consumer Duty for Insurance Brokers and MGAs in 2026
Consumer Duty in insurance is now about evidence of customer outcomes across the distribution chain. Brokers and MGAs must know which part of the outcome they control, share information and act on what claims, complaints and testing show.
Consumer Understanding in Insurance in 2026: What the FCA Expects
Consumer understanding is not satisfied merely because an insurance firm has provided the disclosures required by ICOBS or placed all material policy terms somewhere in the customer documentation.
Consumer Duty for Mortgage Brokers in 2026: What Firms Need to Evidence
Consumer Duty for mortgage brokers is no longer an implementation project. In 2026, the practical question is whether the firm can demonstrate that customers receive good outcomes across the mortgage journey and whether management acts when the evidence shows otherwise.
More guides
- Second Charge Mortgage Compliance in 2026: What Lenders and Brokers Need to Fix
- Mortgage Affordability Assessments in 2026: MCOB 11.6 Controls for Lenders
- Vulnerable Mortgage Customers in 2026: A Practical FCA Framework for Brokers and Lenders
- Consumer Duty for Consumer Credit Firms in 2026: What Firms Need to Evidence
- Consumer Credit Complaints and Redress in 2026: What FCA-Regulated Firms Need to Get Right
- Consumer Duty for Investment and Wealth Firms in 2026: What Firms Need to Evidence
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
PRIN 2A requires firms to act to deliver good outcomes for retail customers. It comprises the consumer principle, three cross-cutting rules covering acting in good faith, avoiding foreseeable harm and enabling customers to pursue their financial objectives, and four outcomes covering products and services, price and value, consumer understanding and consumer support. Firms must monitor outcomes and the board must review an assessment at least annually.
The absence of evidence. Firms can generally describe their intended outcomes but cannot demonstrate them with testing data, particularly on fair value and consumer understanding. Management information that reports activity volumes rather than customer outcomes is the recurring weakness.
A defensible assessment considers total price paid by the customer, including charges applied across the distribution chain, the nature and quality of benefits actually received, differences between customer groups, and whether any group receives materially poorer value. The conclusion must follow from the analysis rather than precede it.
It should set out the outcome monitoring undertaken, the results including areas of poor outcome, the actions taken or planned, an assessment of whether the firm's future business strategy is consistent with the Duty, and a clear conclusion the board can defend. Records should show genuine challenge, not sign-off.
Yes. Where monitoring identifies poor outcomes we help scope the affected population, determine whether redress is required, design the remediation approach, and test that the fix has worked rather than closing the action on delivery.
It can. Firms that can determine or materially influence retail customer outcomes have obligations even where they have no direct customer relationship, which is why distribution chain responsibilities are so important for manufacturers, MGAs and platforms.