Since its formal implementation in July 2023, the Financial Conduct Authority’s (FCA) Consumer Duty has quickly become a defining feature of regulatory expectations in the UK financial services sector. Framed around the principle of delivering “good outcomes for retail customers,” the Duty compels financial institutions to re-evaluate their offerings, processes, and communications. Its four key outcomes—fair value, products and services that meet customer needs, consumer understanding, and customer support—are designed to shift the industry from a culture of compliance to one of customer-centred delivery. 

But where do things stand now? Are firms rising to the occasion, or is Consumer Duty just another regulatory hoop to jump through? 

A shift in attitude, but are we moving fast enough? 

Recent industry events suggest that while some progress has been made, there is still considerable work to do. At The Lang Cat’s “Divide and Conquer 2025” conference, Zara Okoro of the PFS Paraplanning Panel remarked that the Duty has not yet driven radical change across the industry. She argued that financial services remain too complex for everyday consumers to navigate—pointing out that she had to explain annuities to a friend who had already spoken to a professional in the sector. Her concern was not just about product knowledge—it was about the failure of communication, and the urgent need to simplify, personalise, and humanise financial advice. 

Similarly, Samantha Gratton, Chartered IFA at Ellis Davies, highlighted how the Duty is prompting advisers to face uncomfortable truths. Clients increasingly value intangible benefits—like peace of mind and trust—which are harder to measure but central to long-term financial wellbeing. While some of these developments might have occurred without Consumer Duty, Gratton stressed that the regulation shines a spotlight on what it truly means to be a “great planner.” 

In light of mixed feedback, the FCA is reportedly reviewing elements of the Duty to ensure it delivers on its core aims without creating unnecessary burdens. A recent proposal suggests the regulator may ease certain compliance pressures to support business competitiveness while upholding consumer protections. 

This could signal a new phase of regulatory refinement, where enforcement focuses not just on implementation but also effectiveness. However, this shift does not change the underlying expectation: firms must show evidence that they are acting in the best interest of their customers—proactively, not reactively. 

How financial analytics bridges the gap 

For firms navigating the complexities of Consumer Duty, the challenge is clear: how do you ensure a consistent, fair, and tailored service across a diverse and growing client base? 

The answer, in part, lies in digital transformation. Deterministic financial analytics tools offer a powerful route to compliance and innovation. These tools go beyond traditional financial modelling by generating consistent, objective calculations in response to users’ unique circumstances—making them ideal for hybrid advisory models that blend digital self-service with human advice. 

By embedding tools like KidbrookeONE into digital journeys, firms can deliver intuitive simulations that help clients explore their financial futures with confidence. These simulations empower clients to understand the impact of decisions—such as saving more, retiring earlier, or changing investment strategy—without requiring a financial background. It is an approach that not only supports Consumer Duty’s requirement for “consumer understanding” but also fosters trust and transparency. 

The orphaned client problem 

One overlooked area that Consumer Duty brings into focus is the issue of “orphaned clients”—those without an assigned adviser. These clients often fall through the cracks, receiving minimal engagement and potentially breaching regulatory expectations around fair treatment and support. 

Deterministic analytics can play a key role in identifying and supporting these clients. For example, through automated digital journeys powered by financial simulations, firms can provide tailored, consistent advice or guidance—even when there is no assigned adviser. 

This is a valuable commercial opportunity, as by re-engaging orphaned clients with relevant, accessible self-guidance tools, firms can strengthen retention, uncover new needs, and deliver measurable value. 

The future of Consumer Duty compliance lies in combining transparency, personalisation, and automation. Structured analytics can unify disparate datasets and standardise advice across channels, ensuring that all clients receive a consistent level of care—whether they engage via app, online portal, or adviser. By embedding these analytics into client journeys, firms can demonstrate suitability, support informed decision-making, and adapt financial advice or guidance based on changes in life circumstances or risk tolerance. 

This is particularly useful for firms seeking to scale without compromising compliance. Rather than relying on manual assessments, which are prone to inconsistency and oversight, firms can leverage automated analytics solutions that apply the same logic and rules across their entire customer base. 

Turning compliance into a competitive advantage 

For some, Consumer Duty may still feel like a burden—but for those forward-thinking firms, it represents a significant opportunity to differentiate. 

Firms that embrace high-quality financial analytics are better equipped to offer value-driven services that are not only compliant but genuinely customer-centric. By reducing the subjectivity and opacity of traditional financial advice or guidance, models support clearer communication, better engagement, and improved outcomes. 

Moreover, these tools support compliance documentation. Each recommendation, action or projection can be logged, audited, and traced—helping firms prove that they are meeting regulatory expectations around advice suitability, transparency, and ongoing support. 

As we move further into 2025, wealth managers and financial advisers should consider the following priorities to stay ahead of Consumer Duty: 

• Automate for scale: use deterministic financial analytics to deliver consistent advice or guidance to large and diverse client bases. 
• Enhance digital journeys: ensure that your tools are not just compliant—but engaging and accessible to clients of all backgrounds. 
• Support the forgotten:  re-engage with orphaned clients through personalised digital experiences that support their needs and empower self-guided financial journeys. 
• Strengthen evidence: track, document, and audit every financial interaction with clarity and transparency. 
• Measure what matters: focus on the outcomes that align with client values—whether it is peace of mind, sustainability preferences, or long-term planning. 

From obligation to opportunity 

It is clear that the FCA’s Consumer Duty is not going away. At its core, it reflects a growing demand for fairness, transparency, and empowerment in financial services. For firms willing to rethink their models and embrace the power of intelligent financial analytics, the regulation offers a roadmap to better relationships, improved outcomes, and sustainable growth. 

As regulation continues to evolve, those who act now—by embedding structured, scalable solutions will not only remain compliant, but also win client trust in a more competitive, customer-driven landscape.

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