Consumer Duty Implementation Checklist

Products & Services Outcome

• Product inventory completed: all retail-facing products and services listedCreate a complete inventory of every product and service offered to retail customers. This is the foundation of the entire Consumer Duty framework — every subsequent assessment is conducted at the product level. Include products that are no longer actively sold but still have customers in book.
• Target market assessment reviewed and documented for each productFor every product in the inventory, document the target market: who the product is designed for, what needs it meets, and what types of customer would be outside the target market. The FCA expects this to be a substantive assessment, not a box-ticking exercise.
• Product governance framework in place: approval process for new and changed productsThe firm must have a documented process for approving new products and material changes to existing products under Consumer Duty standards. This includes a Consumer Duty sign-off requirement at the point of product approval — not as a retrospective check.
• Features and benefits review: confirm products deliver good outcomes for intended marketConduct a structured review of each product’s features, benefits, and limitations against the needs of the target market. Where a product was designed pre-Consumer Duty, this may reveal features that no longer meet the standard. Document the review and any actions taken.
• Harmful features identified and remediated or flagged for board approval to retainAny feature identified as potentially harmful to the target market must either be remediated (removed or modified) or escalated to the board for explicit approval to retain with documented rationale. The FCA will scrutinise firms that identified harmful features but took no action.
• Product monitoring metrics in place: ongoing data points to evidence the outcome is being metConsumer Duty requires ongoing monitoring, not a one-time assessment. Define the metrics that will evidence the products and services outcome is being met — customer satisfaction scores, complaint rates, product usage patterns, renewal rates. Report these metrics to the board regularly.

Price & Value Outcome

• Price and value assessment conducted for each product: is the price reasonable given the benefitFor every product, document a formal price and value assessment. The assessment must consider the benefits delivered, the costs to the firm of delivering those benefits, and whether the price charged represents fair value. This is not a market comparison exercise alone — it must assess intrinsic value.
• Comparison undertaken against similar products in the marketAs part of the price and value assessment, benchmark each product against comparable products in the market. Document the comparators used and the methodology. Where the firm’s pricing is materially above market, additional justification for the premium is required.
• Vulnerable customer pricing: any differential pricing or fee structures reviewed for fairnessReview whether any pricing or fee structures result in vulnerable customers paying more than other customer segments for equivalent products. This is a specific FCA concern under Consumer Duty — differential pricing that disadvantages vulnerable customers is likely to breach the price and value outcome.
• Fee disclosure: all fees clearly disclosed upfront — no hidden charges or complex structuresReview every customer-facing document, digital journey, and marketing material for fee transparency. All fees — including conditional fees, dormancy fees, exit fees, and foreign exchange margins — must be disclosed clearly before the customer commits. Hidden or unclear charges are a primary Consumer Duty enforcement risk.
• Value assessment documented and signed off by board or senior managementThe price and value assessment must be a formal document signed off at board or senior management level. It should be retained as evidence of compliance. The FCA has indicated that it will request these documents from firms as part of supervisory reviews.

Consumer Understanding Outcome

• Customer communications reviewed: are product terms, risks and fees communicated clearlyReview all customer-facing communications — product terms, key features documents, welcome letters, renewal notices — against the Consumer Duty standard of customer understanding. The test is not whether a lawyer can understand the documents: it is whether a typical customer in the target market can understand them.
• Marketing and financial promotions approved under Consumer Duty standardsAll financial promotions must be reviewed and approved under Consumer Duty standards — including digital ads, social media, comparison site listings, and email campaigns. The Consumer Duty applies to promotions that cause customers to form inaccurate expectations about the product.
• Disclosure documents tested: have real customers reviewed them for comprehensionThe FCA expects firms to test their disclosures with real customers or representative panels, not just rely on internal assessment. Document the testing methodology, the sample used, the findings, and the changes made as a result. Testing with lawyers or compliance teams is not sufficient.
• Complaints analysis: what do complaints reveal about understanding failuresAnalyse the complaints data specifically for patterns that indicate customer misunderstanding of the product. Where complaints reveal systematic misunderstanding — of fees, of product features, of terms — this is direct evidence of a Consumer Understanding outcome failure that requires remediation.
• Digital journey review: is key information prominent, not buried in terms and conditionsMap the full digital customer journey from marketing through to product purchase. Identify every point at which a key piece of information — a risk, a fee, a material limitation — is disclosed. If critical information appears only in the full terms and conditions at the end of a lengthy sign-up process, this is likely to breach the consumer understanding outcome.

Consumer Support Outcome

• Support channels reviewed: is help available in appropriate formats (phone, online, written)Review whether the firm’s support channels are appropriate for the full range of customers in the target market. A digital-only support channel is unlikely to meet Consumer Duty standards for products used by elderly or vulnerable customers. Ensure alternative formats are available and accessible.
• Response time standards set and measured: complaints, queries, account issuesDefine and document response time standards for every category of customer contact — complaints, account queries, security issues, and technical problems. Measure actual performance against these standards and report to the board monthly. The Consumer Duty requires evidenced good outcomes, not stated commitments.
• Vulnerable customer policy: identification, recording, and support adjustments documentedThe firm must have a documented vulnerable customer policy covering how staff identify customers in vulnerable circumstances, how vulnerability is recorded in the customer record, and what support adjustments are made. The policy must be operational — not a document that exists only on paper.
• Switching and cancellation: process is straightforward and well-communicatedReview the switching and cancellation process from the customer’s perspective. Consumer Duty requires that exiting a product is as straightforward as entering it. Cancellation processes that involve multiple steps, lengthy call centre queues, or difficult-to-find contact details are likely to breach the consumer support outcome.
• Escalation process to FOS clearly signposted in customer communicationsThe escalation route to the Financial Ombudsman Service must be clearly signposted in all complaints-related communications. Confirm that the FOS signposting appears in the correct documents — the complaints acknowledgement letter, the final response letter, and the firm’s website — and that the information is accurate and up to date.

Governance & Board Oversight

• Consumer Duty champion appointed at board levelThe FCA requires firms to appoint a Consumer Duty champion at board level. This individual is responsible for ensuring Consumer Duty considerations are embedded in board decision-making. Document the appointment formally — name, date of appointment, and scope of responsibilities — and include it in the firm’s governance records.
• Annual Consumer Duty board report prepared: outcomes monitoring results and remediation actionsThe FCA requires an annual Consumer Duty board report. This report must present the outcomes monitoring data for each of the four outcomes, identify any areas where good outcomes are not being achieved, and document the remediation actions taken. The board must review and approve this report — it is a regulatory document.
• MI pack: monthly metrics measuring each of the four outcomes reported to managementDesign a Consumer Duty MI pack that reports the key metrics for each of the four outcomes on a monthly basis. The metrics must be meaningful indicators of customer outcomes — not proxy measures that look good without evidencing genuine consumer benefit. This pack should feed into the annual board report.
• Third-party oversight: Consumer Duty obligations flowed down to material outsource providersWhere the firm relies on third-party providers for material parts of the customer journey — customer onboarding, payment processing, customer support, technology infrastructure — Consumer Duty obligations must be flowed down contractually. Review all material outsourcing contracts and add Consumer Duty provisions where they are absent.