Consumer Duty for SMFs: Demonstrating Effective Oversight, Challenge & Accountability

Introduction

Most firms have their Consumer Duty implementation behind them. The rules are understood and the frameworks are built. What supervisors now test is narrower and harder. Did senior managers actually challenge what they were shown, and can the firm prove it?

That is a different question from whether the firm complies. A board paper recording that the Duty was considered is not evidence of scrutiny. Nor is a dashboard of activity measures. When the FCA looks at a firm where outcomes went wrong, it looks for the point at which someone should have asked a harder question and for the record of what happened next. Two developments sharpen this. The FCA removed its expectation of a board level Consumer Duty champion in February 2025, which returned the challenge function to the governing body as a whole and to individual senior managers. Separately, the FCA is consulting on the scope and proportionality of the Duty, with final rules expected in early 2027. The boundary of what a senior manager is answerable for is moving and it is moving while firms are being asked to show their working.

This session is aimed at the individual accountability layer rather than the rules themselves. It looks at how a senior manager tests what is put in front of them, what outcomes information is worth relying on and how challenge becomes a durable evidence trail rather than a line in the minutes. It complements general Consumer Duty courses and is intended to follow on.

What You Will Learn

This live and interactive course will cover the following:

• Where accountability for outcomes sits
• How the Duty attaches to a named individual through the Duty of Responsibility
• Governance after the removal of the board champion expectation and what firms are now expected to show instead
• The line between collective board responsibility and individual senior manager accountability
• Challenge that counts
• The difference between confirming the Duty was considered and testing whether it was met
• Questions that expose thin fair value, target market and consumer understanding work
• What to do with a paper that asserts good outcomes without demonstrating them
• Outcomes information a senior manager can rely on
• Activity measures against outcome measures and why supervisors treat them differently
• Reading foreseeable harm in data before it surfaces as a complaints trend
• Building the evidence trail
• Papers, minutes and follow up as the record of your reasonable steps
• The annual board assessment used as evidence of scrutiny rather than as a compliance artefact
• What is changing
• The FCA's current proposals on scope and proportionality of the Duty
• Where to concentrate effort while the final rules are pending

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.