Consumer Duty – does the April deadline apply to you?

There are two Consumer Duty deadlines on the horizon. Firms must take note and action as required.



30 April 2023

The first deadline is 30 April 2023. By this date, Manufacturers should have completed all the reviews necessary to meet the outcome rules for their existing open products and services so they can share with distributors to meet their obligations under the Duty and identify where changes need to be made. See below for further details.

31 July 2023

This is the implementation deadline for new and existing products or services that are open to sale or renewal. It is when all the rules for existing open products and services come into effect for both Manufacturers and Distributors.

Does that mean me?

At this point many readers will be thinking, “We are not a Manufacturer, so I don’t need to worry about the April deadline.” But, before you relax and give up on the rest of this article, beware – many Distributor firms will ALSO be Manufacturers. See below.

As indicated above, implementation of the rules takes effect from 31 July 2023, but the rules and guidance can already be accessed in the FCA Handbook under PRIN 2A. The policy statement can be seen here and the finalised guidance here.

Action required by 30 April 2023

The high-level requirements for the end of April are summarised below.

Manufacturers should aim to complete all the reviews necessary to meet the four outcome rules for their existing open products and services by the end of April 2023. The four outcomes are:

  • Products and Services
    All products and services for consumers to be fit for purpose and be designed to meet the needs, characteristics and objectives of a target group of customers and distributed appropriately.
  • Price and Value
    All consumers to receive fair value. Value is about more than just price, but firms should assess their products and services in the round to ensure there is a reasonable relationship between the price paid for a product or service and the overall benefit a consumer receives from it.
  • Consumer understanding
    Firms’ communications to support and enable consumers to make informed decisions about financial products and services. Consumers to be given the information they need, at the right time, and presented in a way they can understand.
  • Consumer support
    Firms to provide a level of support that meets consumers’ needs throughout their relationship with the firm.

The purpose of the review is so that firms can:

  • share with distributors by the end of April 2023 the information necessary for them to meet their obligations under the Duty (e.g., in relation to the price and value, and products and service outcomes)
  • identify where changes need to be made to their existing open products and services to meet the Duty and implement these remedies by the end of July 2023.

Where firms identify serious issues causing immediate consumer harm, they should prioritise action to remedy this.

Where actions to bring products and services up to Consumer Duty standards can be completed more quickly than the implementation deadlines, firms should consider doing so, to improve outcomes for consumers more quickly.

Definition of ‘Manufacturer’

We hinted above that Distributor firms may also be Manufacturers. We intend to expand on this in another article in the near future but there are some situations where Manufacturer status might apply, for example, firms that operate in-house model portfolios. But that is far from the only scenario. Watch this space for further guidance.

Important Note: ATEB news is intended to provide general information ONLY. The content, including any views expressed or guidance provided, does not replace the need to comply fully with FCA Rules and Guidance. Unless you have discussed news article content with ATEB, and specifically how it relates to your circumstances, then ATEB disclaims all liability and responsibility and actions arising from any reliance placed upon it. For the avoidance of doubt therefore, any reliance you place on such information without our consultation is at your own risk.

ATEB Compliance offers compliance and regulatory advice.

ATEB Suitability provides report writing software for the financial services market.

Our View

The clock is ticking down relentlessly – despite recent press reports, Consumer Duty is not going away and the deadlines are looming.

Action Required By You

Note and action as required. ATEB can help firms to prepare for and implement Consumer Duty. Contact us if you would like assistance.
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About the Author

Technical Manager - Often referred to as the Oracle or the Sage, Alistair has a wealth of financial services experience. He is our go-to Technical Manager and enjoys nothing more than a complicated conundrum. Feel free to test his renowned knowledge by getting in touch.

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