FCA Consumer Duty: What It Means for Your Finance Function

The FCA’s Consumer Duty has been in force since July 2023 for new and existing products and services, and since July 2024 for closed products. Two years into the regime, the FCA is moving from the implementation phase to the outcomes-testing phase — and the firms that treated the Duty as a compliance exercise rather than an operational transformation are now the ones facing the most difficult conversations with their supervisors.

The finance function sits at the heart of Consumer Duty compliance in a way that is not always recognised by the legal and compliance teams who led the initial implementation. This piece explains what Consumer Duty means specifically for the finance team, why the Financial Controller or Finance Director is a key stakeholder in the ongoing compliance framework, and what the FCA now expects to see in terms of financial outcomes monitoring.

What Consumer Duty Actually Requires

The FCA Consumer Duty (PS22/9) establishes a single overarching principle that authorised firms must act to deliver good outcomes for retail customers. The Duty is organised around four outcome areas: products and services, price and value, consumer understanding, and consumer support. Each outcome area has specific requirements, and the FCA expects firms to be able to demonstrate — with evidence — that they are meeting those requirements on an ongoing basis.

The price and value outcome is the one with the most direct finance function implications. Firms must be able to demonstrate that the price consumers pay for a product or service is reasonable given the benefits it provides. For investment managers, wealth managers and insurance intermediaries, this means the finance team needs to be able to produce fee analysis, margin analysis and value assessment data that demonstrates the firm’s pricing is consistent with the Consumer Duty standard. This is not a one-off exercise — the FCA Consumer Duty final rules require firms to review and assess value on an ongoing basis, which means the finance function needs a recurring data production capability, not a one-time project output.

The Finance Function’s Role in Consumer Duty Compliance

The finance team’s Consumer Duty responsibilities are typically underspecified in the compliance framework most firms have built. The legal and compliance teams tend to own the Duty documentation — the implementation plan, the board report, the fair value assessment framework — while the finance team is expected to provide data inputs when asked. This works adequately for the annual board Consumer Duty report. It does not work for the ongoing outcomes monitoring that the FCA now expects.

The FCA’s supervisory focus in 2025 and 2026 has been on outcomes monitoring: can firms demonstrate that actual customer outcomes are consistent with the good outcomes the Duty requires? For the finance team, this translates into a specific data production requirement: the ability to produce, on a regular basis, analysis of fee income, customer retention, product margin, and complaint and redress data that can be read as evidence of customer outcomes rather than just financial performance.

The Financial Controller at a Consumer Duty-regulated firm who understands this requirement — and has built the reporting infrastructure to meet it — is providing risk management value that extends well beyond the standard FC scope. The FC who is unaware of it is leaving the firm exposed to a supervisory finding that the finance team’s data cannot support the Consumer Duty outcomes monitoring the FCA expects.

Price and Value: The FC’s Specific Deliverable

The price and value outcome requires firms to assess whether the price paid by consumers is reasonable relative to the benefits received. For the finance function, this means three specific deliverables.

Product-level margin analysis. The finance team must be able to break down revenue and cost at the product or service level, not just at the firm level. A firm that can demonstrate its overall margin is reasonable but cannot show the margin at the individual product level cannot demonstrate Consumer Duty price and value compliance at the granularity the FCA expects. FCs at firms with complex product sets — multiple share classes, multiple fee structures, multiple distribution channels — may need to invest in management information infrastructure specifically to produce this analysis.

Distribution cost analysis. Where products are distributed through intermediaries, the firm must be able to demonstrate that the total cost to the end consumer — including distribution costs — represents fair value. This requires the finance team to have visibility of the full cost stack, including third-party distribution costs, and to be able to compare total cost against the benefits the product provides.

Fair value assessment documentation. The finance function should be maintaining records of the value assessments performed, the data used in those assessments, and the conclusions reached. These records are the evidence the FCA will request in a Consumer Duty supervisory visit.

Consumer Duty and the Board Report

The FCA requires firms to produce an annual Consumer Duty board report that includes an assessment of whether the firm is delivering good outcomes for customers. The finance team typically contributes the quantitative data sections of this report — the fee analysis, the margin data, the redress and compensation figures.

The board report is increasingly a document that the FCA uses as a supervisory tool — asking firms to share it as part of a thematic review or a firm-specific supervisory visit. The quality of the financial data in the report, and the extent to which it supports a credible assessment of customer outcomes, is a direct reflection of the finance team’s capability.

The FCA has published its expectations for Consumer Duty board reporting in its supervisory communications. The FCA Consumer Duty annual report guidance makes clear that boards are expected to challenge management on the quality of the outcomes data presented, and that the FCA will assess whether the board’s challenge was adequate. This places the finance team’s data quality directly in the supervisory line of sight.

What This Means for FC Hiring at Regulated Firms

The Consumer Duty compliance requirement has added a specific dimension to the FC brief at FCA-regulated businesses that was not present before July 2023. The FC who joins a regulated firm now needs to understand not just the CASS framework, the GABRIEL reporting obligations and the SMCR requirements — but also the price and value analysis, the outcomes monitoring data infrastructure, and the board report contribution that Consumer Duty requires.

This is a material increase in the technical regulatory knowledge requirement for the FC role at regulated firms. Candidates who have worked at an FCA-regulated business since July 2023 and have been involved in the Consumer Duty implementation and ongoing compliance have a significant advantage over candidates who have not. The premium for this experience is real and is reflected in the salary ranges we are seeing for FC roles at Consumer Duty-regulated firms.

See FC at FCA-Regulated Firms, Wealth Management FC, Asset Management FC and CASS Accountant Recruitment for the full regulated firm FC recruitment context.

Consumer Duty compliance is not a one-time project. The FCA has been explicit that it expects firms to demonstrate ongoing good outcomes on a continuous basis, and that the annual board report is the minimum — not the ceiling — of what the FCA expects to see. For finance functions at regulated firms, this means Consumer Duty is now a permanent operational responsibility alongside CASS, GABRIEL and SMCR, not a project that was completed in 2023.

The firms that are managing Consumer Duty most effectively in 2026 are those that invested early in building the finance function capability to support it — the management information infrastructure, the product-level margin analysis, the value assessment documentation. Those firms are now finding that the FCA’s supervisory conversations are more straightforward, the annual board report is less burdensome, and the finance team’s contribution to the firm’s regulatory credibility is visible and valued.

For further reading on the FCA-regulated firm FC role, see FC at FCA-Regulated Firms, SMCR Explained for Finance Teams, CASS Accountant Recruitment and Fintech FC Recruitment.

The FCA’s supervisory communications in 2025 and into 2026 have been consistent on one point: firms that are struggling with Consumer Duty compliance are almost always struggling because they do not have the management information to demonstrate outcomes. The compliance team can write a fair value assessment framework. Only the finance team can produce the underlying financial data that a credible fair value assessment requires. The two must work together, and the FC who understands the Consumer Duty framework — not just as a compliance obligation but as a data production requirement — is the FC who enables that collaboration.

The practical priority for FCA-regulated firms with a Consumer Duty gap in their finance function is not to hire a compliance specialist. It is to hire or develop an FC who combines strong management accounting and financial reporting capability with the specific regulatory knowledge to own the Consumer Duty data production requirement alongside the CASS reconciliation, the GABRIEL returns and the capital adequacy calculation. That candidate exists — but they are in demand and the market for them is competitive. Call 0204 553 8893 to discuss what that search looks like, or see FC at FCA-Regulated Firms and FCA Finance Recruitment.