The FCA signaled its continued focus on Consumer Duty (the Duty) with the launch of its 2025/2026 workplan to prioritise embedding the Duty to ensure better consumer outcomes; this forms part of a wider strategy focus through to 2030 for the regulator. The FCA have set out the focus areas for the coming 12 months and how they expect to see these achieved.

Consumer Duty is no longer just a compliance framework — the continued FCA focus ensures it works as a commercial operating model. In the latest workplan and updates, a key objective was to continue the multi‑firm assessment to test how well the Duty is embedded, with sharper expectations on pricing and value, outcomes monitoring, journey design and vulnerable‑customer support.

As an indicator of the importance of the Duty, the FCA has committed to supporting firms achieve these outcomes as well as working with them to continually increase training and awareness. For secured lenders, the commercial implications are immediate: the ability of lenders to evidence good consumer outcomes increasingly determines growth, retention and reputation.

The FCA’s focus — and what it means for business effectiveness

Embedding the Duty across sectors. The regulator will run thematic, multi‑company reviews to assess real‑world delivery. This is not a paper exercise; it is about demonstrable outcomes across products, and how lenders monitor and improve them. In secured lending, that translates to scrutinising affordability journeys, arrears handling, and end‑to‑end clarity.

Data, monitoring and evidence. The FCA’s review of Consumer Duty reporting from firms identified recurring weaknesses: data quality, distribution‑chain visibility, analysis by customer type, the quality of senior level challenge, and the evidence of action taken. This is a key focus area for the FCA to see improvements from lenders, with greater support being given where practicable.

Price & value under the spotlight. The FCA expects firms to collect robust evidence of fair value and act where products don’t meet the test; a timely reminder that the overarching purpose of the Duty requires financial services firms to put their customers’ needs first. For lenders, that pressures pricing strategy and product design to optimise solutions.

Consumer understanding & journey design. The regulator will review whether communications enable informed decisions and whether customer journeys ensure needs are met and avoid unnecessary friction. Poor design is now both a regulatory and revenue risk.

Vulnerability. Support for customers with characteristics of vulnerability remains a prominent theme. Expect the FCA to look for clear identification approaches, flexible channels, and outcome evidence by customer segment.

Mortgages and secured lending. The FCA has flagged next steps on mortgage and lending expectations and intends to simplify some communications rules while raising the bar on evidence. For commercial lenders, the message is to align profitability aims with provable customer outcomes.

Bottom line: In secured lending, Consumer Duty is the test of commercial discipline. Lenders who evidence outcomes — confidently and continuously — will convert regulatory expectation into market advantage.