Our Consumer Duty focus areas

On this webpage, we set out our priorities under the Consumer Duty for the remainder of 2024/25.

Affected stakeholders will largely be aware of these initiatives, but we are producing this in response to industry feedback that it would be helpful to show our Consumer Duty areas of focus in one place.

Our Consumer Duty focus covers thematic, multi-firm and market-wide work, relevant to a wide set of stakeholders. Most work is not in addition to our usual supervisory activity, but rather a pivot towards the Consumer Duty. We have not included firm-specific supervisory work nor the everyday supervisory work on the Consumer Duty, for example, understanding how firms are delivering good outcomes through the products and services they offer, including looking at any issues around closed products and services.

We have given a short description of the work and expected timelines. Timelines may change, for example, because we need to prioritise new and emerging consumer harms. We also keep these areas under review as pressures emerge on specific sectors or the industry as a whole.

We have prioritised initiatives where:

• We believe sharing more information on good and poor practice and our expectations will benefit industry and help drive better outcomes.
• We see the greatest need to act to address harm – or potential for harm – due to the size or urgency of that harm.  
• We require more data to improve our understanding of the way the Consumer Duty is being embedded.

Based on this prioritisation, we have 4 focus areas for the rest of 2024/25.

Assessing across sectors how firms are implementing and complying with the Consumer Duty

We want to understand how firms are improving consumer outcomes. Where we need more data and information from firms, we’ll only ask for what we need.  

We have 3 cross-cutting projects which we are grouping into packages of publications in Q4 2024 and Q1 2025:

• Review of board/governing body reports and complaints and root cause analysis – Assessing how firms are responding to our outcomes monitoring requirements, for example through our review of Board reports and how firms are using insight from their complaints to identify systemic issues and improve business practices.  
• Review of treatment of customers in vulnerable circumstances – Assessing firms’ approach to the treatment of customers in vulnerable circumstances. 
• Review of consumer support outcome and supporting informed decision-making – Looking at how firms support their customers across the customer journey and how they are using communications to support informed consumer decision-making.

Where we identify good practice, we will share it. Where there are areas for improvement, we will remind firms of our expectations and set out where they may need to accelerate progress. We will combine insights from our work where possible to make it easier for firms to understand what good and poor practice looks like.  If we identify compliance issues, we will consider appropriate action.

We recognise different firms face different challenges. We want firms to take an approach that is proportionate to their size and to the activities they undertake. Where appropriate, we will set out different approaches smaller firms could take.

We know firms have found challenges in conducting fair value assessments and have questions about our expectations. We want firms to use robust analysis to assure themselves, and us, that they are offering fair value, and identify and take action where they are not. In Q3 2024, we published reflections[4] on fair value assessments we have reviewed.  

Further priorities include:

• Platform cash – treatment of interest of cash balances – Tackling concerns about how investment platforms and SIPP operators deal with any interest earned on customers' cash balances[5]. We are engaging with firms where we have concerns.
• Market study into pure protection insurance[6] – Exploring consumers’ engagement with and understanding of the pure protection insurance products they are buying, the competitive constraints on insurers and intermediaries, and firms' incentives, behaviour and practices. We will commence this market study in H1 2025.
• Unit-linked pensions and long-term savings – Looking at transparency of charges across the value chain and how firms assess overall product value. We expect to complete work in Summer 2025 and publish our findings.
• Market study into premium finance[7] – Reviewing whether people who borrow to pay for motor and home insurance are receiving fair, competitive deals. We plan to publish an interim report in H1 2025.

We have planned work to tackle areas of existing concern in sectors across the rest of this financial year and into the next. Firms should expect a general focus on their implementation and embedding of the Consumer Duty and customer outcomes as part of any supervisory engagement.

With the Consumer Duty in force, we published a Call for Input[6] covering our wider requirements on retail firms and asking where we can use the Duty to simplify them. The deadline for responses was 31 October 2024. We will set out next steps in H1 2025.