The Consumer Duty is central to our Putting consumers’ needs first strategic commitment. It sets a higher expectation for the standard of care that firms give consumers.
The Duty came into force on 31 July 2023 for new and existing products and services, and on 31 July 2024 for closed products and services.
Alongside the Duty we undertook a wider programme of work to help firms put consumers’ needs first, set out in more detail in our 2024/25 Annual Report[1].
Suitability and treatment
Suitability and treatment icon
Outcome 1: Consumers are sold products and services that are designed to meet their needs and characteristics
| Metric code | Metric description | Source | Baseline Value | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
CNF1-M01
This metric uses the same data as topline metric CST1-M02 | Reduction over time in upheld Financial Ombudsman Service complaints about unsuitable advice or mis-sold products and services | FCA analysis of Financial Ombudsman Service[2]
| 19,965 Upheld complaints (including PPI) 35% Uphold rate (2021) | 10,106 Upheld complaints (including PPI) 39% Uphold rate (2022) | 7,989 Upheld complaints (including PPI) 33% Uphold rate (2023) | 9,794 upheld complaints (including PPI) 26% uphold rate (2024) | Improved |
15,159 Upheld complaints (excluding PPI) 48% Uphold rate (2021) | 9,679 Upheld complaints (excluding PPI) 40% Uphold rate (2022) | 7,671 Upheld complaints (excluding PPI) 32% Uphold rate (2023) | 9,782 upheld complaints (excluding PPI) 26% uphold rate (2024) | Improved |
Fair value
Fair value icon
Outcome 2: Consumers get products and services which are fair value
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
| CNF2-M01 | Reduction over time in upheld Financial Ombudsman Service complaints about charges, fees and commission and premium pricing | Financial Ombudsman Service[2] | 2,785 upheld complaints, 32% uphold rate (2021) (complaints with any event date)
| 2,241 upheld complaints, 32% uphold rate (2022) (complaints with any event date)
| 1,249 upheld complaints, 27% uphold rate (2023) (complaints with any event date)
| 1,128 upheld complaints, 29% uphold rate (2024) (complaints with any event date) | Improved |
| Financial Ombudsman Service[3] | 1,375 upheld complaints, 28% uphold rate (2021) (complaints with event date in 2020 or 2021)
| 1,032 upheld complaints, 26% uphold rate (2022) (complaints with event date in 2021 or 2022)
| 776 upheld complaints, 24% uphold rate (2023) (complaints with event date in 2022 or 2023) | 691 upheld complaints, 26% uphold rate (2024) (complaints with event date in 2023 or 2024) | Improved | ||
CNF2-M02
This metric uses the same data as topline metric CFV1-M01 | Reduction in the proportion of consumers, including those in vulnerable circumstances, who, in the last 2 years, have been offered a financial product or service they wanted, but at a price, or with terms and conditions, they felt to be ‘completely unreasonable’. We use ‘completely unreasonable’ as it is the question wording in the survey; it doesn’t represent a threshold of what we perceive as fair. We also recognise that the question is asking consumers about their experiences in the past 2 years, so it will take time to show any changes that result from our work.
| FCA Financial Lives Survey (FLS[4])
| 7% of consumers (8% vulnerable, 5% not vulnerable) (2020) | 10% of consumers (10% vulnerable, 9% not vulnerable) (2022)
| 13% of consumers (14% vulnerable, 12% not vulnerable) (2023 re-contact Survey)
| 16% of consumers (16% vulnerable, 16% not vulnerable) (2024) Differences between year 3 and baseline values are statistically significant. | Declined |
Suitability and treatment
Suitability and treatment icon
Outcome 3: Consumers understand the information they are given and make timely and informed decisions as a result
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
| CNF3-M01 | Consumer perceptions of the information they’re given about products and services*
*We added this question to the 2024 Financial Lives survey. The results were available by the end of 2024. The results provide the baseline value. | FCA Financial Lives survey (FLS[5]) | In 87% of the most recent contacts with financial services provider(s), or instances of getting/ finding written information from financial services provider(s) in the last 12 months, what providers told product holders helped them at least a little to make an informed and timely decision or take an action in relation to their financial product. It did not help at all in 13% of cases. (2024) |
| Not assessed |
Outcome 4: Firms provide consumers with good customer support
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
| CNF4-M01 | Reduction over time in upheld Financial Ombudsman Service complaints about administration or customer service, account access, delays and terminations, account closure, cancellation of policies
| Financial Ombudsman Service[6]
| 12,830 upheld complaints 32% uphold rate (2021) (complaints with ay event date)
| 13,092 upheld complaints 33% uphold rate (2022) (Complaints with any event date)
| 14,931 upheld complaints 37% uphold rate (2023). (Complaints with any event date) | 13,791 complaints upheld, 38% uphold rate (2024) (Complaints with any event date) | Declined |
9,668 upheld complaints 32% uphold rate (2021) (Complaints with event date in 2020 or 2021)
| 9,026 upheld complaints 32% uphold rate (2022) (complaints with event dates in 2021 or 2022)
| 12,021 upheld complaints 37% uphold rate (2023) (complaints with event dates in 2022 or 2023) | 11,628 complaints upheld, 38% uphold rate (2024) (complaints with even dates in 2023 or 2024) | Declined | |||
| CNF4-M02 | Maintain or reduce the proportion of consumers (with product(s) in that sector), including those in vulnerable circumstances, who have had a customer service related problem with that product in the last 12 months involving: sales pressure (for consumer credit: pressure to take on additional credit), poor customer service, IT system failure/service disruption, provider errors/not following instructions, delays when making changes to an account, delays when arranging an account, and/ or unsuitable channel (phone, online, face to face) to contact the provider | FCA Financial Lives survey (FLS[7]) | Day-to-day account -12% (vulnerable 13%, not vulnerable 11%) (2020) | Day-to-day account – 10%(vulnerable 11%, not vulnerable 9%) (2022) | Day-to-day account – 17% (vulnerable 21%, not vulnerable 14%) (2023 re-contact survey) | Day-to-day account – 10% (vulnerable 11%, not vulnerable 9%) (2024) Differences between year 3 and baseline values are statistically significant. | Improved |
Mortgages - 6% (vulnerable 7%, not vulnerable 6%) (2020) | Mortgages – 6% (vulnerable 8%, not vulnerable 5%) (2022)
| Mortgages – 6% (vulnerable 8%, not vulnerable 5%) (2023 re-contact survey) | Mortgages – 6% (vulnerable 7%, not vulnerable 5%) (2024) Differences between year 3 and baseline values are not statistically significant. | Little or no change | |||
Regulated credit agreements - 11% (vulnerable 14%, not vulnerable 8%) (2020) | Regulated credit agreements – 10% (vulnerable 14%, not vulnerable 8%) (2022)
| Regulated credit agreements – 8% (vulnerable 11%, not vulnerable 5%) (2023 re-contact survey) Differences between year 2 and baseline values are statistically significant.
| Regulated credit agreements – 12% (vulnerable 15%, not vulnerable 10%) (2024) Differences between year 3 and baseline values are not statistically significant. | Little or no change
| |||
General insurance & protection – 8% (vulnerable 9%, not vulnerable 7%) (2020)
| General insurance & protection – 7% (vulnerable 8%, not vulnerable 6%) (2022)
| General insurance & protection – 8% (vulnerable 10%, not vulnerable 6%) (2023 re-contact survey Differences between year 2 and baseline values are not statistically significant.
| General insurance & protection – 7% (vulnerable 7%, not vulnerable 6%) (2024) Differences between year 3 and baseline values are statistically significant for all customers. Difference between year 3 and baseline values for those with no characteristics of vulnerability or at least one characteristic of vulnerability are not statistically significant. | Improved
| |||
DC pension in accumulation - 6% (vulnerable 7%, not vulnerable 5%) (2020)
| DC pension in accumulation – 5% (vulnerable 7%, not vulnerable 4%) (2022)
| DC pension in accumulation – 8% (vulnerable 8%, not vulnerable 7%) (2023 re-contact survey)
| DC pension in accumulation – 6% (vulnerable 6%, not vulnerable 5%) (2024) Differences between year 3 and baseline values are not statistically significant. |
| |||
DC pension decumulation - 8% (vulnerable 10%, not vulnerable 6%) (2020)
| DC pension decumulation – 9% (vulnerable 10%, not vulnerable 8%) (2022)
| DC pension decumulation – 13% (vulnerable 20%, not vulnerable 8%) (2023 re-contact survey)
| DC pension decumulation – 8% (vulnerable 12%, not vulnerable 6%) (2024) Differences between year 3 and baseline values are not statistically significant. | Little or no change
| |||
Cash savings - 6% (vulnerable 7%, not vulnerable 5%) (2020)
| Cash savings – 7% (vulnerable 9%, not vulnerable 5%) (2022)
| Cash savings – 9% (vulnerable 11%, not vulnerable 7%) (2023 re-contact survey)
| Cash savings – 5% (vulnerable 7%, not vulnerable 4%) (2024) Differences between year 3 and baseline values are not statistically significant. | Little or no change
| |||
Consumer investments - 12% (vulnerable 13%, not vulnerable 11%) (2020) | Consumer investments – 11% (vulnerable 13%, not vulnerable 10%) (2022) | Consumer investments – 8% (vulnerable 13%, not vulnerable 6%) (2023 re-contact survey)
| Consumer investments –12% (vulnerable 15%, not vulnerable 11%) (2024) Differences between year 3 and baseline values are not statistically significant. |
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Confidence
confidence icon
Outcome 5: Consumers have confidence in financial services markets
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Yer 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
CNF5-M01
This metric uses the same data as topline metric CCO1-M01[-12] and metric PFS1-M01 under the Preparing Financial Services for the future commitment | Increase in the proportion of consumers, including consumers in vulnerable circumstances, who slightly or strongly agree that they have confidence in the UK financial services industry | FCA Financial Lives survey (FLS[8]) | 41% of consumers (35% vulnerable, 47% not vulnerable) (2020) | 41% of consumers (33% vulnerable, 49% not vulnerable) (2022) | 43% of consumers (34% vulnerable, 50% not vulnerable) (2023 re-contact survey)
| 39% of consumers (30% vulnerable consumers, 46% not vulnerable consumers) (2024) Differences between baseline value and year 3 values are statistically significant for all consumers or those showing at least one characteristic of vulnerability. Differences between baseline values and year 3 values are not statistically significant for consumers not showing any characteristic of vulnerability. | Declined |
| CNF5-M02 | Increase the proportion of consumers, including consumers in vulnerable circumstances, who slightly or strongly agree that most financial firms are honest and transparent in the way they treat them | FCA Financial Lives survey (FLS[10]) | 34% of consumers (29% vulnerable, 39% not vulnerable) (2020) | 36% of consumers (29% vulnerable, 41% not vulnerable) (2022) | 36% of consumers (29% vulnerable, 41% not vulnerable) (2023 re-contact survey) | 36% of consumers (29% vulnerable, 42% not vulnerable) (2024) Differences between year 3 and baseline values for all consumers and those without any characteristics of vulnerability are statistically significant. Difference between year 3 and baseline values for consumers with at least one characteristic of vulnerability is not statistically significant | Improved |
Access
Access icon
Outcome 6: Appropriate access to financial services is maintained
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
CNF6-M01
| Continued tracking of access to cash given our new statutory powers. | Source: FCA and PSR data request | Access to any bank, building society, Post Office branch, or any ATM (either free or pay-to-use): 95.7% of the UK population are currently within 2km of a cash access point (2021, Q3) Access to cash coverage in the UK 2021 Q3Access to cash coverage in the UK 2021 Q3[12] | Access to any bank, building society, Post Office branch, or any ATM (either free or pay-to-use): 96.5% of the UK population are currently within 2km of a cash access point | Access to any bank, building society, Post Office branch, or any ATM (either free or pay-to-use): 95.1% the UK population are currently within 1 mile of a cash access point | The access to cash coverage in the UK data for 2024 will be published in September 2025. | Not assessed |
99.7% of the UK population are currently within 5km of a cash access point (2021, Q3) | 99.8% of the UK population are currently within 5km of a cash access point | 99.7% of the UK population are currently within 3 miles of a cash access point |
Suitability and Treatment
Suitability and treatment icon
Outcome 7: Firms support consumers to sustainably manage their debts
| Metric code | Metric description | Source | Baseline Value(s) | Year 1 values | Year 2 values | Year 3 values | Latest status (year 3 value compared to baseline) |
|---|---|---|---|---|---|---|---|
| CNF7-M01 | The uphold rate of Financial Ombudsman Service complaints about the treatment of customers experiencing financial difficulties is maintained or reduced | Financial Ombudsman Service[11] | 32% uphold rate (278 upheld complaints) (2020) 35% uphold rate (548 upheld complaints) (2021)
| 24% uphold rate (475 upheld complaints) (2022)
| 27% uphold rate (412 upheld complaints) (2023) | 31% upheld (501 upheld complaints) (2024) | Little or no change |
What the latest metric values tell us
Over our 3-year strategy we set out to achieve the following outcomes:
- Consumers are sold products and services that are designed to meet their needs.
- Consumers get products and services which are fair value.
- Consumers understand the information they are given and make timely and informed decisions as a result.
- Firms provide consumers with good customer support.
- Consumers have confidence in financial services markets.
- Appropriate access to financial services is maintained.
- Firms support consumers to sustainably manage their debts.
We’ve made good progress over the past 3 years.
Complaints about unsuitable advice and mis-selling have gone down (CNF01-M01). The number of complaints dropped significantly between 2021 and 2022 and has stayed low. Fewer upheld complaints may suggest that firms' conduct has improved. This shows progress against our outcome of making sure firms sell their customers products and services that meet their needs.
Upheld Financial Ombudsman complaints about charges, fees commission and premium pricing have also fallen (CNF02-M01). But the Financial Lives survey (CNF2-M02) shows more consumers feel price/terms for financial product(s) or services(s) they have been offered in the last 2 years are ‘completely unreasonable’. So, while we have seen some improvements on fair value, rising costs from inflation and the cost of living may have put additional price pressures on consumers.
On making sure firms provide good customer support, complaints about customer service – like account access, delays, closures, and cancellations – have gone up. More of these complaints are being upheld by the Financial Ombudsman Service too (CNF4-M01). Both metrics were above baseline 2021 figures.
The Financial Lives survey showed little or no change in the proportions of product holders who experienced customer service problems in the last 12 months (CNF4-M02). There were improvements among day-to-day account holders and general insurance and protection policyholders, with fewer consumers experiencing problems. In some financial services sectors, such as mortgages and pensions, where there was little or no change in proportions experiencing these types of problems, this remained low from the outset. As we have not seen any substantial improvements in these metrics, it is clear that there is more to do to ensure consumers receive good customer support.
Consumer confidence in UK financial services has slightly declined (CNF5-M01). This decline may be a reflection of recent economic fluctuations affecting savings, mortgage rates and insurance premiums. However, the proportion of consumers agreeing that most financial firms are honest and transparent in the way they treat them has improved slightly since 2020 (CNF5-M02). This might mean that consumers feel more positive about how financial services firms treat them as customers, even if broader concerns about the UK economy and financial sector affect their confidence in industry.
Upheld complaints about the treatment of customers in financial difficulty (CNF7-M01) improved from the 2021 baseline. The cost of living put pressure on consumer finances, with customers suffering financial difficulty who may not have before. Still, the low number of complaints may show the positive impact of firms’ forbearance measures, and progress in firms supporting consumers to sustainably manage their debts.
We will keep working to help consumers through our new strategy. This includes encouraging product innovation and ensuring fair value (for example, in insurance markets). We will also keep working to ensure the right information, support, and products and services are available to consumers. The Consumer Duty will continue to be at the heart of how we do this. As firms continue to improve their practices as they embed the Duty, we expect continued improvements for customers in financial difficulty.