How we approached Consumer Duty

In 2022, we worked closely with independent consultants to conduct a gap analysis to identify areas of focus for the new Duty and to create a review structure for our program. The following six areas were identified:

  1. Considering Fair Value across all products and services
  2. Testing of Customer Understanding of key communications
  3. Tailoring of Customer Communications
  4. Designing an overarching customer communications framework
  5. Demonstrating customer support and service levels meet the needs of customers
  6. Defining (reasonable) foreseeable harm


This thematic approach has been applied across ‘group-wide’ frameworks and policies relating to the six review areas.

Meeting the deadline for open products

We’re pleased to announce that we have implemented the Consumer Duty requirements across our open products, in line with the FCA deadline of 31 July 2023. This includes the updating of our internal frameworks and policies. You can find more details on our approach for the cross-cutting rules and for the four outcomes below.

You can find a summary of our open products by viewing the link below.

What do you need to do?

Distributors are also required to meet the 31 July 2023 deadline in relation to the open products they offer to clients. The information published by manufacturers at the end of April supported Distributors to assess changes needed to their processes, such as suitability, to demonstrate their compliance with the Duty.  

To date, as we’ve worked through the requirements of the Duty, we did not identify any other management information needed as input to support our work. However, as we continue to embed the changes we’ve made, if we do identify anything further is needed, we’ll contact distributors to let them know. If a distributor identifies any concerns or requires additional information of our open products, the firm should let us know as soon as possible.

Our approach to the cross-cutting rules

The Consumer Duty cross-cutting rules define the standards of outcomes we align to; acting in good faith, avoiding foreseeable harm, and helping customers achieve their financial objectives.

The four outcomes

We have worked through the four outcomes of the Duty in relation to our open products to establish the changes or enhancements needed. Click on each section to find out more detail of our approach and outcomes.

More material to help you

You'll find further reading and a wide range of support material on the FCA website

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