Consumer Duty Isn’t a Policy — It’s a Culture

The FCA’s Consumer Duty has prompted significant change across regulated firms.

But many organisations approached it the wrong way.

They asked:
“What policy do we need to write?”

Instead of:
“What needs to change?”

Consumer Duty Is About Behaviour

You can write:

• A fair value framework
• A vulnerability policy
• A board attestation statement

But if behaviour doesn’t shift, nothing really changes.

Consumer Duty is about:

• Decision-making
• Product design
• Customer communications
• Outcomes monitoring

It’s about how a firm behaves when no one is watching.

Board Ownership Is Critical

In my experience across consumer credit and insurance sectors, the firms that approach Consumer Duty successfully do one thing differently:

They treat it as a governance issue — not a compliance task.

Boards ask:

• What evidence do we have of good outcomes?
• Where are customers struggling?
• Are we measuring what matters?

When leadership engages meaningfully, culture follows.

Culture Is Built Through Structure

Culture doesn’t mean slogans on walls.

It means:

• Clear accountability
• Measurable outcomes
• Regular challenge
• Honest reporting

It means compliance isn’t a department — it’s embedded in operations.

Consumer Duty isn’t about producing documentation for the FCA.

It’s about building a firm that would still treat customers fairly even if no regulator existed.

That’s when compliance becomes defensible.

And more importantly — sustainable.