What is Consumer Duty?

In practice, Consumer Duty requires firms to assess how AI systems affect the customer journey, from marketing and onboarding through decisioning, servicing, complaints handling, and vulnerability support. Compliance teams should test whether AI outputs are fair, understandable, and capable of producing good outcomes across customer segments, and they should maintain governance over data quality, model change management, human oversight, and complaint escalation where automated tools are used.

The FCA expects firms to evidence that products and services are designed and monitored with customer outcomes in mind, which makes AI governance a conduct issue as well as a technology issue. This is especially relevant where AI is used in retail financial services, such as credit, insurance, investment, and customer support, and it aligns closely with broader UK expectations on operational resilience, governance, and treating customers fairly.