MorganAsh comments on Consumer Duty third anniversary

31 July 2026

Andrew Gething, managing director of MorganAsh, said:

“The third anniversary of Consumer Duty marks the next phase of maturity as expectations sharpen and focus shifts from implementation into action and outcomes. Over the past year, significant milestones have demonstrated this shift, from the FCA and ICO’s joint call to collect and share vulnerability data to new CII guidance on customer vulnerability management and data privacy.

“Combine this with the FCA’s emphasis on proactive identification of vulnerability and its recent review highlighting weaknesses in outcomes monitoring and the direction of travel is clear: the focus is moving beyond whether firms have implemented Consumer Duty to whether they can evidence consistently good customer outcomes. With increasing regulatory intervention and a rise in Consumer Duty-related whistleblowing, expectations on all fronts have never been clearer.

“For too long, some firms have viewed Consumer Duty primarily as a regulatory obligation. The next phase is all about recognising its wider potential. Those investing in robust, digitally-enabled customer vulnerability management can generate better quality data, build a deeper understanding of customers’ needs and deliver more personalised support. This is where the competitive advantage and commercial gains can be realised – all from staying closer to clients and delivering the products, services and support that actually meet their needs.”