Consumer Duty | Where Do Firms Stand?

The FCA’s Consumer Duty is now fully operational and the latest findings show that many firms are failing to meet regulatory expectations. The FCA has made it clear that non-compliance will result in interventions and firms should take this as a warning.

Under the Duty, businesses must demonstrate that they are acting in the best interests of their customers; ensuring fair treatment, transparent pricing and proactive risk management. The FCA has already highlighted FX pricing transparency, fee structures and governance failures as key areas of concern in the payments sector.

Ignoring these requirements will likely result in regulatory scrutiny, direct enforcement actions, financial penalties and reputational harm. Firms should be conducting detailed compliance audits, improving data reporting and ensuring that Consumer Duty considerations are embedded from the top down, starting at board level.

For firms, the below should be at the top of their to-do list:

• Review pricing structures: ensure FX pricing, fees and terms are transparent and easily understood by customers.
• Strengthen governance: is Consumer Duty embedded at board level, with clear accountability for decision-making?
• Enhance data reporting: businesses must be able to evidence compliance, so regular monitoring and audits are key.
• Assess customer outcomes: are firms proactively identifying and supporting vulnerable customers rather than relying on reactive measures?
• Train staff on Consumer Duty obligations: front-line teams should understand the regulatory expectations and be equipped to apply them in real scenarios.

With FCA supervision ramping up in 2025, businesses that embed these requirements now will be in a stronger position when regulators come knocking.

Edmund is already helping firms integrate Consumer Duty into their compliance frameworks. Get in touch today to ensure your business meets FCA expectations.

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