The new Consumer Duty which comes into force in July 2023 requires firms to act in good faith towards, and avoid foreseeable harm to, retail customers. The rules are aimed at enhancing the FCA’s consumer protection and competition objectives.

Firms will need to provide information that customers can understand, offer products and services that are fit for purpose and give helpful customer advice. In short, the focus is on achieving good customer outcomes.  

Delivering good customer outcomes requires the right products and processes to be in place, which impacts on governance arrangements and people policies, including training, performance management, pay and incentives policies, all of which will need to reflect the new Consumer Duty requirements.

There are also a number of changes to the individual Conduct Rules. Staff will need to be aware of the FCA’s expectations and SMFs will be expected to ensure that the Duty obligations are met in the areas for which they have responsibility and that appropriate supervision structures and SMCR responsibilities are in place for global operations.  

HR and those with People responsibilities will have a critical role to play in embedding a cultural focus on good customer outcomes bearing in mind the Duty’s primary cultural drivers: Purpose, Leadership, People and Governance.

Deloitte Legal can help with the identification, review and navigation of these new requirements and the actions needed to become compliant. In addition, we can leverage the expertise from other service lines across Deloitte to ensure a holistic package of support for clients in meeting their people related Consumer Duty obligations.

For an informal discussion about how we can help, please speak to your usual Deloitte Legal contact or get in touch with the team.

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