Why This Matters
The FCA’s latest update confirms that the Consumer Duty remains the centrepiece of regulation for 2025–2030.
Rather than introducing new prescriptive rules, the regulator is doubling down on embedding the Duty as the primary framework for good outcomes – deepening trust, rebalancing risk, and promoting sustainable growth.
For regulated firms, that means the bar is rising again. The focus now shifts from implementation to evidence: proving that customers are genuinely receiving fair value, clear communication, and the right support throughout their journey.
Four Cross-Cutting FCA Projects for 2025/26
To assess how effectively firms are delivering outcomes under the Duty, the FCA will conduct four thematic, multi-firm reviews:
- Products and Services
Evaluating how firms design products to meet customer needs, particularly for those with characteristics of vulnerability.
Example: One protection broker recently simplified its add-on disclosure scripts after user-testing with vulnerable customers revealed confusion around optional cover. - Outcomes Monitoring
Assessing how firms collect and use MI to measure customer outcomes across the Duty’s four areas: products and services, price and value, consumer understanding, and customer support. - Customer Journey Design
Reviewing how firms identify and remove friction points that could disadvantage less-engaged or vulnerable consumers. - Consumer Understanding
Testing whether communications genuinely support informed decisions – especially around exclusions, costs, and promotional offers.
The FCA will also continue to share examples of good and poor practice through its multi-firm reviews, helping firms benchmark progress and reduce uncertainty without adding new layers of regulation.
Key Themes to Prepare For
1. Fair Value Under Scrutiny
Fair value remains a major area of focus.
Firms are expected to demonstrate robust methodologies for assessing value and to take swift corrective action when poor value is identified.
The FCA has multiple ongoing reviews:
- Pure protection insurance: Interim report due late 2025, examining consumer understanding and intermediary incentives.
- Premium finance: Continued scrutiny following interim findings in July 2025.
- Unit-linked pensions and long-term savings: Focus on charge transparency and overall product value.
💡 If you’re reviewing your fair value frameworks, Voyc’s QA insights can help identify where value gaps may be emerging.
2. Vulnerability and Data Protection
In collaboration with the ICO, the FCA will publish joint guidance in early 2026 on how firms can balance vulnerability support, data sharing, and GDPR compliance.
This aims to clarify grey areas that have caused hesitation or inconsistency in support processes.
Firms that evidence clear, proportionate approaches to data sharing for vulnerable customers will be well positioned once this joint guidance lands.
3. Evidence of Embedding the Duty
Supervisory activity in 2025/26 will increasingly focus on closed books, legacy products, and outcomes evidence.
Firms should expect data requests, but the FCA emphasises proportionality. Smaller firms are encouraged to demonstrate progress in ways that suit their scale and business model.
Sector Focus: Where the FCA Will Be Looking Closely
Beyond these cross-cutting priorities, the FCA has also highlighted several sector-specific areas of concern.
Firms in these markets should expect direct supervisory engagement:
- Consumer Finance – How well customers understand credit card terms and promotional offers.
- Retail Banking – Fair value and consumer understanding in SME business current accounts.
- Consumer Investments – Vulnerability identification by wealth managers and advice suitability.
Wholesale Buyside – Implementation of the Duty in model portfolio services (MPS), with findings expected in summer 2026.
Five Actions Compliance and Ops Leaders Should Take Now
1. Strengthen Outcomes Monitoring
Review your MI dashboards to ensure they go beyond compliance — showing whether customers actually experience good outcomes. Include metrics like complaints, persistency, switching rates, and closed-book outcomes.
2. Revisit Fair Value Frameworks
Stress-test methodologies across your product range, especially for protection, premium finance, and long-term savings. Be ready to explain how value is assessed and evidenced at board level.
3. Audit Customer Journeys
Map out potential friction points that may impact vulnerable or less-confident customers. Use testing to prove that communication, timing, and access routes are fair and proportionate.
Clarify Vulnerability and Data Practices
Prepare for the FCA/ICO joint guidance by documenting how you currently handle data sharing for vulnerable customers, and where processes may need adjustment.
Engage the Board Early
Conduct a board-level gap analysis against the four FCA cross-cutting projects.
Ensure board packs include clear Duty MI and evidence of challenge and action.
The Bottom Line
The FCA’s 2025/26 focus signals a maturing phase of the Consumer Duty.
The emphasis has shifted from “doing” to “demonstrating.” Firms that can show consistent, evidence-based outcomes will not only satisfy the regulator, they’ll strengthen customer trust and competitive position.
Forward-looking compliance and operations leaders are already:
- Linking QA insights directly to outcomes MI,
- Stress-testing customer journeys for friction and vulnerability, and
- Using conversation intelligence to surface evidence for board reports and audits.
The firms that treat Duty evidence as a strategic advantage, not just a compliance task, will be the ones who thrive under the FCA’s next phase.
How Voyc Ensures Accurate Transcription
At Voyc, transcription accuracy is built into every stage of our compliance monitoring process. We combine specialised speech models trained on financial conversations with human-in-the-loop validation to ensure transcripts are precise, explainable, and FCA-ready.
Our platform automatically detects speaker changes, flags low-confidence segments for review, and continuously improves through supervised learning — so even complex accents, vulnerable conversations, and noisy environments are captured accurately.
All data is processed within secure, FCA-aligned environments under ISO 27001 certification and full GDPR compliance.
The result: a reliable, transparent transcription layer that powers fair outcomes, consistent QA, and confident Consumer Duty evidence.
