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The upcoming rollout of Ireland’s revised Consumer Protection Code (CPC) has sparked cross-border conversations about the direction of consumer regulation. In the UK, it is fast approaching a year since the Consumer Duty began applying across all products, both open and closed. Nearly twelve months on, questions remain: are firms embedding the Duty into their culture, or reverting to old habits behind a fresh layer of compliance?
For UK firms, this is a useful moment to assess how far you’ve come, and how far you still need to go, on delivering good customer outcomes in practice.
A quick recap
The FCA’s Consumer Duty came into force in two phases:
It represents a wholesale shift in regulatory expectations, requiring firms to demonstrate that they are delivering fair value, transparent communications, and appropriate support to customers at all stages, not just at point of sale.
Key observations since full implementation
1. Focus on outcomes, not just process
The emphasis on real-world customer outcomes has changed the way firms think about compliance. It’s no longer enough to follow procedures; firms must now be able to show that customers are achieving good outcomes across pricing, communication service and support.
2. The closed book challenge
Adding closed products to the scope in July 2024 brought legacy systems and dormant accounts into sharp focus. Firms have had to assess whether longstanding customers, often those least engaged, are receiving fair value and appropriate communications, even if they haven’t interacted with the firm in years.
3. More scrutiny from the Regulator
The FCA has spent the past two years emphasising support and guidance, encouraging firms to get their frameworks in place and culture aligned. That tone is shifting. Supervisory engagement in recent months has focused more sharply on evidence and accountability. The FCA has made it clear it will not hesitate to act where it sees harm, or where firms cannot show they are actively avoiding it.
A key area to watch in the coming months will be pricing practices and fair value assessments, especially in sectors where “loyalty penalties” or longstanding pricing disparities may be embedded in closed books.
Why the cross-border comparison matters
The ongoing overhaul of Ireland’s CPC offers a clear reminder: the trend toward outcome-focused, consumer-first regulation is not unique to the UK. In fact, the Irish proposals bear strong similarities to the Consumer Duty in terms of their emphasis on customer understanding, fair value and the treatment of vulnerable customers.
Firms operating in both jurisdictions must now navigate two evolving regulatory regimes with overlapping, but not identical, requirements. This makes robust governance, consistent MI, and strong internal alignment more important than ever.
What should UK boards be considering now?
Nearly twelve months into full implementation, UK boards should be asking:
If the answer to any of these is uncertain, it’s time to revisit your firm’s Consumer Duty strategy.
The year ahead
2025 will be the first full year of closed product compliance, and the first real test of whether firms are embedding the Duty beyond initial implementation. The FCA has indicated it expects continuous improvement, not static frameworks. Enforcement is likely to follow where firms fall short.
With parallel reforms progressing in Ireland, there’s also value in learning across borders. Firms that operate in both markets have a unique opportunity to develop consistent, principles-based approaches to customer protection, rather than duplicating efforts jurisdiction-by-jurisdiction.
Looking for support?
If you’re navigating UK Consumer Duty compliance, or preparing for Ireland’s CPC reforms, our cross-jurisdictional Financial Regulation team is well-placed to assist.
Date published: 23 May 2025
