Policy Briefing — July 31, 2025
The UK FCA expects Consumer Duty boards to sign off 31 July 2025 outcomes assessments with MI, fair value remediation, and vulnerable customer evidence ready for supervisor challenge.
Executive briefing: The Financial Conduct Authority’s Consumer Duty (PRIN 2A) requires firms to deliver an annual board-level report evaluating how retail products, services, and support meet the four outcome tests. The FCA set July 31 each year as the deadline for completing and approving the report, and supervisors have warned they will request 2025 packs as evidence that firms embedded lessons from the first closed-product milestone in 2024. Boards must be ready to defend product governance, fair value assessments, and root-cause remediation actions covering data gathered throughout the 2024/25 financial year.
Board deliverables
- Outcome dashboards. Refresh product, price, support, and consumer-understanding metrics with clear thresholds, trend analysis, and links to remediation backlogs.
- Closed-book evidence. Document how legacy product enhancements, communications, and exit support improved outcomes for customers who were originally outside the 2023 go-live scope.
- Management actions. Capture accountable executive ownership, deadlines, and investment requirements for any Consumer Duty gaps so supervisors can track delivery post-July.
Data and controls
- Vulnerable customer analytics. Segment complaints, servicing interactions, and arrears data to demonstrate improved outcomes for vulnerable cohorts as emphasised in FCA portfolio letters.
- MI governance. Evidence data provenance, lineage, and control testing for dashboards feeding the board report, aligning with the FCA’s expectations on reliable management information.
- Third-party oversight. Include Consumer Duty clauses in distribution and servicing contracts, and summarise partner testing so outsourced journeys remain within tolerance.
Regulatory engagement
- Supervisor readiness. Prepare briefing packs, data extracts, and remediation trackers to supply within 48 hours if the FCA issues an evidence request.
- Training and culture. Record board and senior manager training, culture metrics, and incentive adjustments supporting Consumer Duty embedding.
- Disclosure alignment. Synchronise the board report with ESG, climate, and diversity disclosures so public statements mirror Consumer Duty commitments.
Sources
- FCA Policy Statement PS22/9: A new Consumer Duty
- FCA 2024 Dear CEO letter on Consumer Duty implementation
Zeph Tech structures Consumer Duty board packs—aligning MI governance, remediation accountability, and supervisor engagement scripts ahead of the July 2025 review cycle.