Consumer Duty update: 4 key themes for financial services

Annie Mannion | 30 Sep 2026

The Financial Conduct Authority (FCA) has published a series of new reviews and good practice updates that reinforce a familiar message: Consumer Duty is about delivering and evidencing good customer outcomes, not simply meeting compliance requirements.

This aligns closely with AbilityNet's existing guidance that accessibility, inclusion and customer understanding are fundamental to achieving good outcomes.  

1. Legacy pension and savings products under scrutiny 

The FCA's latest multi-firm review of unit-linked pensions and savings products found that customers in older, legacy products are more likely to receive poorer value than those in newer products. Common issues included higher charges, lower investment returns and access to fewer features. 

While the FCA highlighted examples of firms reducing charges, simplifying products and improving customer outcomes, it expects that providers review whether they can genuinely demonstrate fair value or act promptly if they cannot. 
Report cover: Text reads 'Consumer Duty Insight Report' 10 practical insights to help the financial sector deliver better customer outcomes

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2. Updated Consumer Duty good practice guidance 

The FCA has refreshed its Consumer Duty guidance on: 

  • Consumer support 
  • Complaints and root cause analysis 
  • Price and value assessments 

The updates include practical examples and additional insights for smaller firms. The regulator says it will continue expanding its library of Consumer Duty best practice resources throughout the year.

A woman sitting on a sofa uses a laptop while holding a debit card, preparing to make an online payment3. Product design must focus on customer outcomes 

A separate FCA review examined how firms design, monitor and distribute products and services. The regulator found some organisations are making positive changes, but good practice is not yet being applied consistently. Firms are expected to: 

  • Design products with customer needs in mind from the outset 
  • Regularly review whether products remain suitable 
  • Take responsibility for outcomes even when third parties distribute products 

The FCA is encouraging firms to assess whether their governance and product design processes are truly delivering good customer outcomes in practice. 

4. Stronger outcomes monitoring expected 

The FCA has also reviewed how firms monitor Consumer Duty outcomes. It highlighted examples of organisations using evidence-based approaches to identify risks, understand customer experiences and take action before harm occurs. However, it found significant room for improvement across the sector.  

For accessibility professionals, this reinforces an important Consumer Duty principle: firms need evidence that customers can successfully access, understand and use their products and services.

AbilityNet's Consumer Duty research has consistently highlighted the importance of testing with real users, monitoring outcomes and demonstrating continuous improvement, particularly for disabled customers and those with additional support needs.

What this means for accessibility teams 

These latest FCA updates strengthen the case for accessibility as a core part of Consumer Duty compliance. Financial services firms should be asking: 

  • Can we evidence that all customers achieve good outcomes? 
  • Are we monitoring accessibility-related customer friction and complaints? 
  • Do older products, services and communications contain barriers that newer ones have addressed? 
  • Are we using customer insight and inclusive user research to inform product improvements? 

As the FCA continues to focus on outcomes, firms will need to demonstrate not only that they have accessibility policies and processes in place, but that customers can successfully use their products and services in the real world. 

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AbilityNet works with banks, insurers, fintechs and regulators to create digital services that are accessible, inclusive and usable for all customers.
"AbilityNet assesses each project and its requirements, provides excellent guidance and support to the team, and delivers fantastic outputs which are detailed and actionable" - Brian Grellmann, Aviva
Find out how AbilityNet can help your organisation build accessible and inclusive financial services. 
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Sources: FCA Regulation Round Up, July 2026 and Consumer Duty price and value practices article

Further resources for Financial Services Teams