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FCA Consumer Duty: implications for UK insurance intermediaries - fair value, data-led compliance, implementation (open and closed), vulnerable customers, communications/support, commissions, claims and renewals, board reporting, and supervisory expectations

Practice notes
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This Practice Note explores the ramifications of the Financial Conduct Authority’s (FCA) Consumer Duty for insurance intermediaries, covering the assessment of fair value in insurance products, the FCA’s expectations for rollout, and a range of intermediary-specific considerations linked to scheme policies, placing and producing brokers, claims handling and renewal activity, broker remuneration and potential insurer conflicts. It also signposts key regulatory developments (including supervisory reviews) that are pertinent to intermediaries’ delivery of the Consumer Duty. For an overview of the core components of the FCA’s Consumer Duty, see Practice Note: The FCA Consumer Duty—essentials. For commentary on what the Duty means for insurers, see Practice Note: The FCA Consumer Duty—implications for insurers. For significant milestones on the Consumer Duty, including go-live dates, see: The FCA Consumer Duty—timeline.

FCA’s reviews into value measures

Under the Consumer Duty, firms must achieve and test four outcomes, which include judging the price and value of their offerings. The FCA has made clear that firms should perform fair value assessments to evidence that what a consumer pays for a product or service is proportionate to the overall benefits they are likely to obtain. Further to the announcement of the...

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Web page updated on 21/05/2026

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