Built from the FCA Consumer Duty Act

Practical frameworks for Consumer Duty compliance that actually work

We've turned the Consumer Duty regulation into actionable, structured frameworks — so you can move beyond tick-box compliance toward genuinely better customer outcomes.

4
Integrated Frameworks
6
Design Pattern Cards
4
FCA Outcomes Covered
The Frameworks
Four frameworks, one integrated approach
Each framework addresses a distinct dimension of Consumer Duty compliance. Together, they give you a complete, evidence-based operating model for demonstrating good customer outcomes.
01
📊

Consumer Duty Evidence Framework

Transform how you capture, analyse, and present compliance evidence to boards and regulators. Move from reactive data-gathering to a structured evidence architecture.

Evidence ArchitectureBoard ReportingMaturity AssessmentGap Analysis
02
🛡️

Vulnerable Customer Operating Model

Embed vulnerability considerations into every customer touchpoint with identification triggers, graduated response protocols, and outcome monitoring.

Identification TriggersSeverity MatrixResponse ProtocolsTraining Framework
03
🔬

Customer Understanding Testing at Scale

Systematically measure, monitor, and improve customer comprehension using behavioural science, journey testing, and multi-method assessment.

Behavioural TestingComprehension MetricsA/B TestingSegment Strategies
04
🔗

Third-Party Assurance Model

Ensure your entire distribution chain — brokers, MGAs, TPAs, repair networks — meets Consumer Duty standards through structured oversight and assurance.

Distribution ChainAssurance StandardsContract RequirementsPerformance SLAs
Framework 01

Consumer Duty Evidence Framework

A structured evidence architecture that transforms how insurers capture, analyse, and present Consumer Duty compliance evidence.

Evidence Data Architecture

  • Customer Journey Data — Policy inception, ongoing relationship, claims experience, policy conclusion
  • Outcome Measurement Data — Product suitability, price & value analysis, consumer understanding results, support service levels
  • Third-Party Performance Data — Distributor sales patterns, TPA service levels, repair network performance

Monitoring & Analysis Engine

  • Automated Monitoring — Real-time dashboards, trend analysis, comparative analysis, exception alerts
  • Predictive Analytics — Early warnings, customer journey analysis, vulnerable customer predictions, fair value modelling
  • Board Reporting Package — Quarterly Consumer Duty report template, executive dashboard, deep-dive analysis, action planning

Gap Analysis & Remediation

  • Evidence Maturity Assessment — 8-dimension scoring across data capture, analysis, governance, documentation, regulatory readiness, proactive monitoring, action orientation, stakeholder communication
  • Remediation Planning — Capability building roadmap, implementation support, prioritised action plans
Framework 02

Vulnerable Customer Operating Model

A comprehensive operating model that embeds vulnerability identification, graduated response, and outcome monitoring across every customer touchpoint.

Identification Trigger Points

  • Digital Channels — Application patterns, behavioural signals, communication preferences, policy management patterns
  • Voice Channels — Customer disclosure, speech patterns, communication difficulties, emotional distress indicators
  • Claims Journey — Life event claims, vulnerability disclosed during process, extended claims duration, third-party involvement
  • Third-Party Sources — Broker/distributor protocols, TPA identification, special addresses, power of attorney records

Vulnerability Categories

  • Health — Physical disability, mental health conditions, cognitive impairment, terminal illness
  • Life Events — Bereavement, relationship breakdown, job loss, caring responsibilities
  • Resilience — Financial difficulty, low financial capability, digital exclusion, low confidence
  • Communication — Language barriers, sensory impairment, learning difficulties, low literacy

Technology & Tools

  • ML models for pattern-based vulnerability detection
  • NLP for real-time vulnerability indicator analysis
  • Voice analytics with speech pattern recognition
  • Third-party database integration for proactive identification
Framework 03

Customer Understanding Testing at Scale

Systematic measurement of customer comprehension using behavioural science, multi-method testing, and continuous optimisation.

Behavioural Journey Testing

Real decision-making scenarios, eye-tracking studies, think-aloud protocols, and task completion analysis that reveal how customers actually experience your products.

Comprehension Assessment

Pre/post knowledge testing, scenario-based decision tests, risk comprehension evaluation, and comparative product understanding measurement.

A/B Communication Testing

Multi-variate testing of communications, cross-segment testing, channel optimisation, and longitudinal tracking of understanding over time.

Real-World Validation

Post-purchase comprehension surveys, complaint correlation analysis, claims experience assessment, and switching behaviour analysis to validate testing in practice.

Framework 04

Third-Party Assurance Model

Structured oversight ensuring your entire distribution chain meets Consumer Duty standards — from brokers and MGAs to TPAs and repair networks.

Assurance Standards

  • Vulnerability identification training requirements for all third parties
  • Service standards aligned to your Consumer Duty outcomes
  • Referral protocols for identified vulnerability
  • Standardised reporting and escalation frameworks

Contract Requirements

  • Mandatory Consumer Duty clauses for all distribution agreements
  • Performance SLAs with outcome-based metrics
  • Right-to-audit provisions and monitoring frameworks
  • Remediation obligations and escalation procedures

Ongoing Monitoring

  • Distributor sales pattern analysis for target market compliance
  • TPA service level monitoring against Consumer Duty outcomes
  • Repair network performance tracking and customer feedback
  • Regular assurance reviews with structured reporting

Why This Matters

The FCA is clear: firms cannot outsource their Consumer Duty obligations. You remain responsible for outcomes delivered through your distribution chain. This framework gives you the assurance architecture to demonstrate that oversight.

Design Pattern Cards — Sample Selection
Practical patterns for recurring compliance challenges
Below are six examples from our growing pattern card library. The full library spans three principle families, multiple organisational levels, and is continuously expanding as new compliance challenges emerge. Each card addresses a specific, recurring problem — providing a structured solution that works at the right level.
💡 A small selection from our wider pattern card collection
Consider All Customers

The Hidden Market

Business Model
The problem: Firms optimise products for a "typical" customer, inadvertently excluding or disadvantaging significant population segments.
The pattern: Systematically map target, adjacent, and excluded populations. Design products that serve the edges, not just the centre — expanding your addressable market while meeting duty obligations.
Working when: Product teams can articulate who they're not serving and why; exclusion decisions are evidence-based and documented.
Consider All Customers

The Vulnerability Triage

Operating Model
The problem: Vulnerability responses are binary — either nothing happens or every case gets the same intensive treatment, overwhelming specialist resources.
The pattern: Route customers by severity to proportionate responses. Four-level triage ensures the right support reaches the right people without over-engineering every interaction.
Working when: Specialist case volumes are sustainable; routine vulnerability is handled confidently by front-line teams.
Consider All Customers

Declining with Dignity

Operating Model
The problem: When customers are declined or excluded, they hit a dead end — no explanation, no alternatives, no onward pathway.
The pattern: Structure post-decline journeys with clear explanations, alternative product suggestions, and referrals to appropriate providers or support services.
Working when: Declined customers can articulate why they were declined and what their options are; complaint volumes from declines fall.
Consider All Customers

Reading the Room

Engagement
The problem: Vulnerability is only identified when customers explicitly disclose it — missing the majority who show signs without saying the words.
The pattern: Design every touchpoint to detect vulnerability signals — behavioural indicators, contextual clues, and disclosed information — creating multiple opportunities to identify and respond.
Working when: Identification rates increase; proportion identified through signals (not just disclosure) rises significantly.
Consider All Customers

Designed for the Edges

Engagement
The problem: Accessibility and vulnerability accommodations are bolted on as exceptions, creating inconsistent experiences and operational complexity.
The pattern: Use the needs of vulnerable customers as the design baseline. When you design for the edges, the centre benefits — simpler language helps everyone, not just those with low literacy.
Working when: Mainstream customer satisfaction improves alongside vulnerable customer outcomes; fewer "special process" exceptions needed.
Demonstrating Good Outcomes

No Surprises

Engagement
The problem: Customers discover material limitations — exclusions, conditions, excess amounts — only when they try to use the product, leading to harm and complaints.
The pattern: Surface material limitations proactively before commitment at every key moment: purchase, renewal, and claims. Make the "what you're not covered for" as clear as "what you are."
Working when: Claims disputes about "I didn't know" decline; customer understanding scores on exclusions improve measurably.

Each pattern card operates at a specific organisational level — Business Model, Operating Model, or Engagement — so you can see exactly where in your organisation the change needs to happen. Cards include cross-references to related patterns, evidence and supporting facts, and an AI automation lens showing where technology can accelerate implementation.

The cards are designed to sit between the regulation (which tells you what) and your implementation (which is specific to your firm). They give you the “how to think about it” layer that's often missing.

Full Pattern Library

There's more where these came from

The full library includes 20+ pattern cards across three principle families — Consider All Customers, Demonstrating Good Outcomes, and Embedding Customer-Focused Culture — covering Business Model, Operating Model, and Engagement levels. Each card includes cross-references, evidence callouts, watch-outs, and an AI automation lens.

Open the Pattern LibraryBrowse the full library
The Triple Alignment Framework
From compliance cost to competitive advantage
Most firms treat Consumer Duty as a regulatory cost. The Triple Alignment Framework shows how the same investments can drive commercial value — if you align them properly.
Stage 1

Compliance Theatre

Separate policies, bolt-on training, tick-box mentality. High cost, low value — you spend money proving compliance without improving outcomes.

  • ❌ Fragmented investment
  • ❌ Duplicate effort across teams
  • ❌ Regulatory risk remains high
Stage 2

Integrated Compliance

Processes embed Consumer Duty requirements. Staff are empowered, metrics are integrated, cross-functional working is the norm.

  • ✓ Embedded processes
  • ✓ Integrated metrics
  • ✓ Cross-functional working
Stage 3

Competitive Advantage

Consumer Duty drives innovation. Inclusive design expands markets, customer intelligence becomes a strategic asset, and the investment becomes a profit centre.

  • ✅ Innovation through constraint
  • ✅ Market expansion
  • ✅ Brand differentiation

1. Regulatory Treadmill vs. Strategic Investment — Data integration for monitoring becomes a Customer 360 platform. Process flexibility becomes operational agility. Cultural empowerment becomes genuine customer-first culture.

2. Efficiency vs. Experience — Simplified processes (designed for cognitive accessibility) complete faster for everyone. Plain language drives higher engagement. Flexible verification reduces abandonment.

3. Product Innovation vs. Risk Management — Inclusive design mitigates risk while expanding addressable markets. Edge-case testing catches product issues early. Accessibility features become mainstream competitive advantages.

Most firms invest £2–5m annually across CX, data, risk, product, and training teams — often duplicating effort across these functions. By aligning investment around Consumer Duty outcomes, firms can extract 30–40% more value from the same spend by eliminating duplication and creating shared capability.

Taster Assessment
Where does your firm stand?
Answer five quick questions to get a snapshot of your Consumer Duty readiness across the key dimensions. This is a taster — for a comprehensive assessment, you can take the full version.
How does your firm currently capture Consumer Duty compliance evidence?
This explores your evidence architecture maturity.
Ad hoc

We gather evidence reactively when regulators or boards ask for it

Structured but manual

We have templates and processes, but it's largely spreadsheet-driven

Partially automated

Some dashboards and automated data capture, but gaps remain

Fully integrated

Automated evidence capture across all four outcomes with real-time dashboards

Connected Thinking
How the frameworks work together
These aren't four separate projects — they're an integrated system. Each framework generates evidence and insight that strengthens the others.

📊 Evidence Framework

Captures and structures the evidence generated by all other frameworks

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🛡️ Vulnerable Customers

Generates identification data, response records, and outcome evidence

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🔬 Understanding Testing

Tests comprehension across segments including vulnerable customers

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🔗 Third-Party Assurance

Extends all framework standards across your distribution chain

Consider a customer who is recently bereaved and making a life insurance claim through a broker:

  • Vulnerable Customer Operating Model identifies the bereavement trigger and routes to Level 2/3 response protocol
  • Customer Understanding Testing has already validated that claims communications work for customers in stress states
  • Third-Party Assurance ensures the broker follows the same identification and response protocols
  • Evidence Framework captures the full journey — identification, response, outcome — creating a documented evidence trail for board and regulator

No single framework delivers that outcome alone. The integration is what makes it work.

Ready to explore what this means for your firm?

We bring these frameworks — fully developed and ready to adapt — to every engagement. Let's talk about where you are and where you need to be.

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