The FCA’s Consumer Duty isn’t new—but as we enter its second full year, expectations are rising fast. Firms regulated for consumer credit can no longer rely on policies that simply ‘tick the box’.
What’s Changing in 2025?
By 31 July 2025, firms must:
- Complete their second annual Consumer Duty Board Report
- Evidence of measurable improvements in customer outcomes
- Take action on gaps, failures, and inconsistencies identified during year one
Boards and senior managers must now ‘own’ Consumer Duty performance—not just delegate it to compliance teams.
The FCA’s Expectations Are Clear
The regulator wants to see:
- Customer outcome metrics tracked across all four duty outcomes
- Evidence of product & service reviews
- Analysis of vulnerable customer journeys
- Actual change—not just intent
It’s not just about having a framework—it’s about proving it works.
Risks for Non-Compliance
The FCA has said that 2025 will see greater supervision and enforcement.
Areas at risk:
- Consumer credit firms relying on legacy affordability models
- Lenders or brokers with no end-to-end outcome monitoring
- Digital journeys that leave customers misinformed or exposed
- Board reports with insufficient MI or no challenge from non-execs
ALPH Legal & Compliance’s View – Time for a Rethink
Many firms rushed to implement Duty policies in 2023. But few have integrated outcome-based thinking into day-to-day governance, QA and culture.
2025 is the year this gets tested.
That means:
- Making MI usable at the senior level
- Revisiting target market assessments
- Mapping actual vs intended outcomes
- Investing in customer feedback loops
- Auditing affordability decisions and friction points
How ALPH Can Help
At ALPH Legal & Compliance, we offer:
- Consumer Duty audits and gap analysis
- Annual Board Report drafting and assurance
- Vulnerable customer journey testing
- Conduct and culture training
- Independent challenge to MI, governance and product reviews
Final Word
The FCA expects better in 2025—and that’s not just talk.
Firms that lead on conduct will outperform.
Those who lag will find themselves under the microscope.
ALPH Legal & Compliance can help you evidence not just compliance, but leadership.
With all the regulatory shifts on the horizon, now is the time to act. Don’t wait until compliance gaps appear—engage with Alph Legal today to ensure your firm is ahead of the curve. Whether you need tailored guidance, compliance support, or strategic insights to drive new business, Alph Legal is your trusted partner in navigating FCA regulations with confidence.
Visit Alph Legal & Compliance now and take control of your compliance future!