In proposing the Consumer Duty, the FCA pinpointed several issues relating to insurance, including the value of add-on products, price and value generally, and the loyalty penalty.

The Consumer Duty is designed to usher in an approach to customers that mitigates the risk of similar issues emerging and reduces the need for sector-specific rules in future.  It takes an outcomes-based and largely sector-agnostic approach to regulation.

But insurance firms will need to apply it to their businesses specifically, navigating overlapping rules and the (somewhat knotty) ways that legacy products may be impacted, and working out how in practice to implement a renewed focus on the entire customer journey by insurers and distributors alike.

Want more insights and support?  Read our more detailed note, and follow the links in that note to our additional resources - as well as to reach out to us to discuss.