Reflecting on the FCA’s Consumer Duty focus areas for 2026

Since Consumer Duty was introduced, financial services companies have spent time building frameworks, updating policies, and training teams.

But with the legislation now firmly embedded across the industry, the key question has shifted from ‘Are we compliant?’ to ‘Can we actually show customers are getting better outcomes?’ It’s the difference between writing the policy and demonstrating the policy works in practice.

Evidence remains the key factor

The FCA clearly recognises that most companies have put solid governance and oversight in place. But the regulator is looking beyond structure and control. It wants proof that these frameworks are improving real customer experiences. Are consumers getting fairer products, clearer communications, or better support?

This approach can only be positive, ensuring that Consumer Duty works in practice rather than just in theory. But it also raises challenges. Internal dashboards and MI often only show what the business expects to happen, not what customers actually experience. It’s a bit like looking at claims ratios and assuming that means customers felt supported through the claims journey. The numbers don’t tell you if someone felt helped or left out in the cold when they needed you most.

Understanding that gap is where the real work begins.

Embedding Consumer Duty is more than just listening

When the FCA talks about ‘embedding’, it doesn’t mean just tracking outcomes. It means making sure customer feedback genuinely influences decisions.

Too often, insight is gathered but not acted on. The companies that will perform well under Consumer Duty are those that use real customer feedback to refine their products and adjust their approach when something isn’t landing.

And yes, we may be biased, but independent and specialist insight is key here. It helps companies see things from the customers’ eyes, not just the internal view of how things ‘should’ be working.

Value and understanding under scrutiny

The FCA has highlighted two focus areas where companies will need strong evidence: price and value and consumer understanding.

Value is not just about whether a product is ‘fairly priced’. It’s about whether customers feel they’re getting fair value. For example, a savings account could be competitively priced, but if the rate changes without clear explanation, customers may still feel short-changed. Value is emotional as well as financial, and that perception alone can become an outcome concern.

Likewise, communication is only effective if customers genuinely understand it. If customers interpret messaging differently than intended, companies need to know that – and fix it quickly.

Again, that’s why credible customer review data really matters. Internal self-assessments aren’t enough.

The power of customer insight

With more than 2.7 million verified reviews, Smart Money People is the UK’s most comprehensive financial services review site, helping companies understand where customers feel valued or frustrated. Unlike other platforms, we focus solely on financial services, with 16+ data-points captured with every review. This level of insight gives a clearer view of what’s working and what needs improvement, supported by real customer voices.

Ultimately, it helps shift conversations from ‘We believe outcomes are good’ to ‘here’s the data that shows it.’

Final thoughts

Consumer Duty has sometimes been seen as an extra compliance burden. But those who embrace it have a real opportunity to stand out. When a business acts on its feedback and can evidence the impact – it builds trust. And trust is a huge competitive advantage.

The FCA will look at outcomes. So will customers. And so will the market.

Those that can evidence fair value and improved customer experience won’t just meet expectations, they’ll earn loyalty and strengthen their reputation in the process.

Read the full FCA update here.

To discover how our data can help you to evidence Consumer Duty outcomes, contact our Business Development team.