Our Consumer Duty focus areas

Our Duty focus areas cover thematic, multi-firm and market-wide work, relevant to a wide set of stakeholders.  

We’ve not included firm-specific supervisory work nor the everyday supervisory work on the Duty. For example, understanding how firms are delivering good outcomes through the products and services they offer, including looking at any issues around closed products and services.

We’ve given a short description of the work and expected timelines. These may both change if we need to prioritise new and emerging consumer harms for specific sectors or the industry.

We’ve prioritised initiatives where:  

• We can share more information on good and poor practice and our expectations to help industry deliver better outcomes.  
• We see the greatest need to address actual or potential harm.  
• We need more data to understand how firms are embedding the Duty and delivering good consumer outcomes.
• There are opportunities to streamline our rules, reduce burden on businesses and improve outcomes for consumers. 

To understand how firms are improving consumer outcomes, we intend to carry out a handful of multi-firm projects to look at how the Duty is being embedded across sectors.  

We may ask for data, but only when we need it. And we’ll offer feedback where firms need help with implementation.

We recognise different firms face different challenges. We want firms to take an approach that is proportionate to their size and to the activities they undertake. Where appropriate, we’ll set out different approaches smaller firms could take.

In 2025/26 we have 4 cross-cutting projects:  

• Review of products and services outcome – How firms are designing products and services to meet customer needs, including those with characteristics of vulnerability.  
• Review of firms’ approaches to outcomes monitoring – How firms are responding to our outcomes monitoring requirements.  
• Review of firms’ customer journey design – Looking at the design and delivery of firms’ customer journeys to ensure customers’ needs are met, with a particular focus on how firms apply friction throughout the journey.
• Review of the consumer understanding outcome – How firms’ communications are helping consumers make informed decisions.  

Through joint engagement with the Information Commissioner’s Office (ICO), we have heard that some firms can struggle to balance how to meet their vulnerability, data sharing, and data protection expectations.

Together with the ICO, we will provide further clarity on the interaction between these expectations in Q1 2026.

We know firms have come across challenges when conducting fair value assessments and have questions about our expectations.  

We want firms to use robust analysis to offer fair value, and to identify and take action where they are not.

Our priorities include:

• Market study into pure protection insurance[7] - Exploring consumers’ engagement with, and understanding of, the pure protection insurance products they are buying, the competitive constraints on insurers and intermediaries, and firms' incentives, behaviour and practices. We expect to publish an interim report and proposed next steps around the end of 2025.
• Unit-linked pensions and long-term savings – Looking at transparency of charges across the value chain and how firms assess overall product value. We expect to publish our findings later in 2025.  
• Market study into premium finance[8] – Reviewing whether people who borrow to pay for motor and home insurance are receiving fair, competitive deals. We published interim findings in July 2025.  

We’ve planned work to tackle areas of existing concern in sectors where there may be harm, or the potential for harm.  

Firms should expect a general focus on their implementation and embedding of the Consumer Duty and customer outcomes as part of any supervisory engagement.