Three years in, the question is no longer whether a firm has implemented the Consumer Duty, but how well. The FCA has now shown, in considerable detail, what separates weaker programmes from stronger ones.
When the Consumer Duty came into force, most firms faced the same task: document how each product and service met the new standard, and do so in time. That phase is over. The FCA has since published reviews, good practice and areas for improvement on every outcome, from products and services to consumer support, and on board reporting and outcomes monitoring. It has moved from explaining the Duty to supervising and enforcing it, and in July 2026 it reported 11 investigations into potential breaches.
Read together, those publications draw a clear line. On one side are programmes that document the Duty. On the other are programmes that use it. The difference is rarely effort. It is maturity.
Four stages of maturity
In our work with firms across banking, payments, credit and wealth, we see Consumer Duty programmes fall into four broad stages.
Reactive. The Duty sits in a handful of generic policies. Complaints are sampled, fair value is asserted rather than analysed, and the board sees the Duty once a year.
Defined. The work is documented product by product: target market, journeys, harms and fair value. Each piece, however, stands on its own. Metrics are mostly lagging, and board reports are heavy on data and light on conclusions.
Connected. Harms, vulnerability, value and support are tied to journey stages and the distribution chain. Every metric has an owner and a tolerance, every finding is closed out, and the board reads a clear account of each outcome. This is where the FCA’s published good practice points.
Strategic. Journeys are tested continuously, every complaint is classified, and outcome insight informs product design, pricing and operations. This reflects the strongest examples in the FCA’s reviews, and it is where the Duty begins to pay for itself.
Few firms sit at a single stage. A firm can be Connected on governance and still Reactive on consumer support. The value of a maturity model lies in seeing those differences clearly, element by element, rather than settling for a single overall verdict.
The gap most firms need to close
Many of the firms we speak to sit at Defined on several elements. They have done real work, and their documentation is often thorough, but documentation alone is not what the FCA describes as good practice. The gap between Defined and Connected lies in the links between documents, not in the documents themselves.
Three signs suggest a programme has stalled at Defined. The target market, journey map and harms register were each written once, often by different people, and none of them changes when the product does. The firm reports a great deal of MI, but could not say which metric would warn it of which harm, or who would act if that metric moved. Issues are logged and actions agreed, but no one returns to confirm that the outcome for customers actually improved.
The FCA’s own findings echo this. Its July 2026 review of outcomes monitoring makes the point that collecting data, listing metrics or reporting MI will not, on its own, show whether customers receive good outcomes. What does is a clear line from data to risk, from risk to action, and from action to a measurable improvement. Vulnerability tells a similar story: in the FCA’s 2025 survey, only 29% of firms said they tested the impact of a product or service on customers with characteristics of vulnerability.
Why maturity pays
Most of the cost of the Duty today lies in compiling evidence rather than judging it. In our conversations, one firm needed four to five hours to test a single customer case, most of it spent assembling notes, calls and documents. Another firm told us their monthly board pack takes days to assemble and its annual Consumer Duty report takes weeks, sometimes months.
A connected programme changes that. When the record of products, journeys, harms and metrics is already joined up, the review, the board report and the outcomes test start from evidence that already exists. Compliance teams spend their time exercising judgement rather than assembling information.
It also changes what a firm finds. When we analysed one firm’s documents and evaluated them against their website, we discovered that the representative APR was stated differently in different places and corrected it. Another found that its own materials described a service as in scope when it believed it was not. Each was a poor outcome caught early, before it became a complaint, redress or a remediation exercise.
Where to start
The fastest route to Connected begins with products and monitoring, because every other element draws on them. Take your highest-risk product and map each foreseeable harm to the journey stage and distribution channel where it arises. Then map each metric you report to the harm it is designed to detect. Any harm without a metric, and any metric without a harm, is the first gap to close.
From there, the same discipline extends to fair value, consumer understanding, support and the board narrative. It also prepares a firm for what comes next. CP26/23 proposes a more proportionate Duty, with board reporting that can use existing governance and the FCA expects to make any new rules in Q1 2027. That may change how firms report. It will not change what they must be able to evidence.
How Relace helps
Relace turns Consumer Duty into a competitive advantage. For firms new to the Duty, we build the programme from the ground up, to the Connected standard from day one. For firms with a programme already in place, we analyse and evaluate it against the maturity model, identify where the links are missing and implement the fixes, building on the work already done. In both cases the programme is built, evidenced and maintained within Relace, without lengthy integrations or a sustained call on product, operations and data teams. In our experience, firms reach the same standard in less than half the time, and at less than half the cost, of a traditional consulting engagement.
Read the full white paper
Our white paper, Where Do You Really Stand? The Consumer Duty Maturity Model, sets out the full model across seven elements. For each, it explains what the FCA expects, where firms most often fall short, what best-in-class looks like and the first step towards Connected, with practical examples throughout. It includes a self-assessment your team can use to place your firm on every row.
Download the white paper to see where your programme stands today, or get in touch to talk through where your firm sits and what it would take to move it forward.