Since the Financial Conduct Authority (FCA) formally introduced Consumer Duty in July 2023, the regulation has significantly influenced how UK financial institutions approach customer outcomes.
Its core mandate—to ensure “good outcomes for retail customers”—has forced firms to rethink the way they design products, deliver services, and communicate. The Duty’s four outcomes—fair value, suitable products and services, consumer understanding, and adequate support—are intended to push the sector beyond box-ticking and towards genuine customer-centred service.
Kidbrooke, a unified analytics platform for investment and wealth, has delved into consumer duty and how to turn the regulation into an opportunity.
Despite its ambitions, the Duty’s impact has been mixed. At The Lang Cat’s “Divide and Conquer 2025” event, Zara Okoro from the PFS Paraplanning Panel suggested that meaningful change is lagging. She highlighted persistent complexity in the industry, citing the example of having to explain annuities to a friend who had already consulted a professional, Kidbrooke stated. For Okoro, the issue isn’t just technical knowledge—it’s about improving how advice is communicated so that clients can understand and trust it.
Similarly, Ellis Davies chartered IFA Samantha Gratton pointed out that intangible factors like peace of mind and trust are often what clients value most. These harder-to-measure outcomes are becoming essential to what makes a good planner, with Consumer Duty acting as a catalyst to bring them into focus.
In response to ongoing challenges, the FCA is reportedly considering tweaks to the Duty. Proposals aim to reduce overly burdensome compliance requirements while keeping the core objective intact. However, this does not change the fundamental expectation: firms must demonstrate, with evidence, that they are proactively acting in their customers’ best interests.
Technology is increasingly seen as a solution to bridging the gap between regulation and delivery. Deterministic financial analytics tools offer a structured approach to delivering consistent, personalised, and transparent advice. Unlike traditional modelling, these tools generate objective calculations tailored to each client, making them ideal for hybrid models that combine digital access with human insight. Tools like KidbrookeONE can simulate a range of outcomes—such as changes in investment strategy or early retirement—helping clients better understand and engage with their financial decisions.
One particularly under-addressed area is the issue of “orphaned clients”—those who are not actively served by an adviser. These clients risk falling below regulatory expectations for support and engagement. However, digital solutions can enable firms to reach these clients with tailored journeys and guidance, even without human interaction. This not only mitigates regulatory risk but opens up new opportunities to engage underserved segments and uncover unmet needs.
The combination of analytics, personalisation, and automation enables firms to scale their operations while maintaining compliance. By standardising logic and decision rules across their platforms, institutions can offer consistent service via apps, online portals or advisers—regardless of client channel or profile. It’s an approach that promotes both operational resilience and fairness.
Far from being just another compliance headache, Consumer Duty offers forward-looking firms a competitive edge, Kidbrooke explained. With the right tools in place, they can deliver client outcomes that are not only compliant but meaningful. These tools also simplify documentation and auditing processes, providing clear records to demonstrate suitability, support, and transparency.
Looking ahead, firms should focus on scaling advice through automation, designing more accessible digital experiences, re-engaging neglected clients, and using analytics to track and evidence client outcomes. In doing so, they not only comply with regulation but create lasting client trust and value.
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