FCA reinforces product design expectations under Consumer Duty
FCA published guidance emphasising the importance of effective product design in delivering good consumer outcomes, citing diverse consumer needs from Financial Lives data.
The FCA is reiterating that product design is central to Consumer Duty outcomes, highlighting variability in consumer resilience and capability. Firms should expect continued supervisory scrutiny of product governance, target market definition, and evidence that products are designed with real consumer needs rather than assumed 'standard' customers.
Reinforces FCA supervisory focus on product governance and Consumer Duty outcomes across retail financial services.
Action Required
Review product governance and target market assessments to evidence design accommodates diverse consumer needs and vulnerabilities.
Signals ongoing supervisory emphasis on Consumer Duty product design, informing thematic review and enforcement priorities.
Revisit product approval processes and fair value assessments. Ensure target market definitions reflect diverse consumer needs including vulnerable customers, and document evidence of design decisions for supervisory challenge.
“Financial products and services shape some of the most important decisions we all make. Our Financial Lives data shows a huge spread of needs, resilience and capability. That's why it's so important for firms to design their products effectively. When firms have consumers' needs firmly in mind, they can support good outcomes.”
Published: 2026-07-31