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The FCA Consumer Duty: How we can help

How A&O Consulting can help you meet the challenge of the wider ranging set of requirements and regulatory expectations for the Consumer Duty.

Application of Requirements

  • Analysis and advice on the application of the rules to your business model, including current and closed business lines and products.
  • QA on your interpretation of the application of the Consumer Duty requirements.
  • Advice on embedding the Consumer Duty into your culture and identifying drivers of good and poor behaviour.

Target operating model, gap analysis, implementation

  • Design and/or review of measures required to meet requirements, in a manner that is sustainable and practical for business.
  • Perform and/or support gap analysis of existing processes, policies and procedures against required measures
  • Implementation of enhancements required, identified through gap analysis

Product and Proposition Design and Approval

  • Design and/or review of your product and proposition design and approval frameworks, ensuring good customer outcomes are central and considering the four outcomes.
  • Review and identification of current and closed products and policies which do not meet the new requirements.
  • Analysis of the customer journey, including product selection and value and customer communications.

Board Oversight

  • Design and/or review of the approach to reporting, escalation and management information for the Board.
  • Tailored training for the Board on the implication of the Consumer Duty’s requirements, to ensure that they are equipped to provide appropriate oversight and challenge to achieve good customer outcomes
  • Review of the Board’s processes for assessing future business strategies, to ensure that the Consumer Duty is embedded long-term.


  • Tailored training for Senior Management on the implications of the Consumer Duty and the COCON rules, to ensure they are equipped to deliver good outcomes for retail customers
  • Support in the mapping of Senior Management function holder roles and responsibilities, in particular considering the four outcomes.
  • Review of the approach to reporting and incident escalation.


  • Design and review of monitoring and outcomes reporting frameworks to identify issues with implementation as they arise.
  • Design, review and implementation of a testing framework centred around the four outcomes and the prevention of foreseeable harm.
  • Review of the governance and policies for monitoring across the lines of defence.