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12 July 2023

Greater Clarity Needed on Consumer Duty Rules Ahead of July Implementation Deadline 

Attendees at a recent behind-closed-doors Insurance DataLab roundtable shared their thoughts on how the industry was progressing ahead of the Consumer Duty implementation deadline

The session involved a number of people responsible for implementing Consumer Duty, including representatives from AXA, Covea, First Central and Freedom Services Group, as well as legal and compliance experts. 

The session started with a call for greater clarity from the FCA around what the rules require from insurance companies. 

One attendee stated that while they believe their firm is ahead of the curve when it comes to progress towards implementation, it is still hard to determine whether that will be enough in the eyes of the regulator as the requirements are simply not clear enough. 

They said that the regulator needs to provide the industry with clear and simple messaging laying out their expectations, as without that it is impossible to achieve the cultural buy-in that is needed for the spirit of Consumer Duty to become embedded within an organisation. 

One of the compliance experts agreed with this sentiment but also offered some reassurance. 

They said that the good firms in the industry will already be fulfilling a lot of the requirements, now they just need to evidence it – although that may be easier said than done – with deciding which metrics to monitor being of upmost importance. 

Another attendee said that they have already seen Consumer Duty creeping into existing FCA investigations, with price and the relationship that has to the value being delivered being particularly instrumental in the regulator’s decision-making. 

They said that this is especially important for smaller firms with a small product suite, as if the FCA decides a particular product is not offering fair value, then that could have a significant impact on the overall business. 

Commission payments were also raised as another area the FCA is looking into, with insurers required to explain any outliers that were drawing particularly large commission payments to distributors. 

Evidence Essential 

An insurer representative said that one of the challenges they are facing is how to present the evidence the regulator needs, and how it is all aggregated into a coherent dashboard. 

The approach they’re taking is to align specific metrics that they were already measuring to the individual outcomes relating to Consumer Duty, and then finding any gaps in monitoring that require additional metrics to fulfil the regulations. 

It was also highlighted that complaints handling is an issue raised specifically by the FCA, with the regulator expecting companies to understand how they are performing relative to the wider market, and then performing root-cause analysis to better understand any failings. 

The good news, however, is that none of the attendees see the 31 July deadline as a final cut-off point for Consumer Duty where the regulator expects all issues to be sorted by. 

Instead, firms must have identified any existing issues that may fall foul of the regulations and have a credible plan in place for corrective action and ongoing monitoring and benchmarking of the situation. 


  • Branko Bjelobaba, compliance consultant 
  • Claire Carpenter, compliance consultant 
  • Sally Clarke, First Central 
  • Craig Gibson, First Central 
  • Vicki Heslop, Covea 
  • Rachel Hillier, Capital Law 
  • Poppy Hindley, AXA 
  • David Williams, Freedom Services Group 
  • Dan King, Insurance DataLab 
  • Matt Scott, Insurance DataLab 

Insurance DataLab’s insight platform includes a number of metrics that help with monitoring performance under Consumer Duty, including FOS and FCA complaints handling statistics, FCA value measures and customer experience ratings. Apply for a free trial now. 

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