Capability - Consumer Duty

Consumer Duty Consultants: Expert Support for Regulated Firms

The FCA's Consumer Duty represents the most significant shift in UK conduct regulation in over a decade. At Square 4, we help regulated firms not just comply with the Duty, but embed it into their culture, operations and governance - turning regulatory obligation into competitive advantage.

Our team includes former FCA supervisors and industry practitioners who understand the Duty from every angle. We've supported firms across banking, insurance, wealth management and consumer credit to design, implement and evidence good customer outcomes.

Why Consumer Duty Expertise Matters Now

The FCA has made clear that Consumer Duty is not a one-time compliance exercise. Firms must continuously demonstrate they are delivering good outcomes across the four key areas:

Products and services – designed to meet customer needs
Price and value – fair value for the benefits provided
Consumer understanding – clear, timely communications
Consumer support – accessible, responsive service

The regulator is actively supervising against these outcomes. Firms that cannot evidence compliance face enforcement action, s166 skilled person reviews, and reputational damage.

Yet many firms are still struggling with:

Outcomes monitoring – capturing and analysing the right data
Fair value assessments – particularly across complex distribution chains
Board reporting – providing meaningful MI that enables challenge
Embedding the Duty – moving beyond policy to genuine cultural change

Our Consumer Duty Services

We offer a comprehensive range of Consumer Duty support, tailored to your firm's size, sector and maturity:

Consumer Duty Health Checks
Bespoke framework design covering the full complaints lifecycle: complaints definition and identification procedures, investigation and resolution quality standards, root cause analysis, governance structures and escalation routes, MI dashboard design and KPIs, quality assurance and risk management. We deliver comprehensive process and policy design, complaints training materials and a governance framework ready for implementation. Our health checks include gap analysis against PRIN 2A requirements, review of outcomes monitoring framework and MI, assessment of fair value methodology and documentation, evaluation of vulnerable customer identification and support, board and governance effectiveness review, and a comprehensive report with prioritised recommendations.
Outcomes Monitoring Design & Implementation
Effective outcomes monitoring is the cornerstone of Consumer Duty compliance. We help firms design and implement monitoring frameworks that identify the right metrics across the customer journey, capture data efficiently from existing systems, establish meaningful thresholds and triggers, enable proactive identification of poor outcomes, and support board-level reporting and challenge.
Fair Value Assessments
Price and value is a key FCA focus area. We support firms to define and document target markets with appropriate granularity, assess total cost to customer, including distribution chain impacts, analyse cross-subsidies and differential pricing, benchmark against market comparators, and document and justify fair value conclusions.
Board Reporting & Annual Assessment
The FCA expects boards to actively oversee Consumer Duty compliance. We help firms design board MI packs that enable meaningful challenge, prepare for and facilitate annual board assessments, draft Consumer Duty annual reports, and train board members and senior management on their responsibilities.
Consumer Duty Training
Embedding the Duty requires understanding at all levels. We deliver tailored training for board members and senior management, first line teams (sales, service, operations), second line compliance and risk functions, and third line internal audit.

Sectors We Support – Our Consumer Duty expertise spans:

Banking & Building Societies – mortgage lending, savings, current accounts, credit
Insurance – general insurance, protection, distribution chains
Wealth Management & Investment – advice, investment management, platforms
Consumer Credit – affordability, forbearance, fair value requirements

Why Square 4

Award-Winning Expertise

Square 4 was named Compliance Consultancy Firm of the Year 2024 by the International Compliance Association - recognised for delivering an award-winning Outcomes Testing Framework.

FCA Perspective

Our team includes former FCA supervisors and senior industry practitioners who understand how the regulator thinks, what good looks like, and how to evidence it.

Practical, Commercial Focus

We build solutions that work within your operating model, technology environment and resource constraints - solutions your teams can actually use.

Relationship-Driven Approach

We build long-term partnerships with our clients. Many engage us for initial health checks and stay for ongoing retained support.

Frequently Asked Questions

What is the FCA Consumer Duty?

The Consumer Duty is a regulatory framework introduced by the FCA in July 2023, requiring firms to deliver good outcomes for retail customers. It comprises a Consumer Principle (PRIN 12), cross-cutting rules, and four outcomes covering products/services, price/value, consumer understanding, and consumer support.

Who does Consumer Duty apply to?

Consumer Duty applies to all firms in the distribution chain that can influence retail customer outcomes – not just those with direct customer relationships. This includes product manufacturers, distributors, intermediaries and platforms.

What is a Consumer Duty health check?

A Consumer Duty health check is an independent assessment of your firm’s compliance with the Duty. It typically includes review of policies, processes, outcomes monitoring, fair value assessments, and governance arrangements.

How often should we conduct Consumer Duty reviews?

The FCA expects ongoing monitoring and at least annual board-level assessment. Many firms conduct quarterly health checks on specific areas and comprehensive annual reviews.

How can Square 4 help with Consumer Duty compliance?

We offer comprehensive support including health checks, outcomes monitoring design, fair value assessments, board reporting, training and implementation support. Our services are tailored to your firm’s sector, size and specific needs.