2026: When Consumer Duty Moves from Framework to Proof
Over the past year, we’ve seen a noticeable shift in how Consumer Duty is being supervised.
Firms aren’t being asked whether they have a framework anymore. They’re being asked to show, in real time, that it’s working. That’s a very different conversation.
The FCA’s focus is increasingly practical. Not policy design. Not documentation quality. But whether firms can consistently evidence good customer outcomes, particularly for vulnerable customers, at scale.
And that raises some uncomfortable questions for leadership teams:
Can you demonstrate that affordability assessments are working as intended?
That customer communications are genuinely clear?
That vulnerability is identified early and supported appropriately?
That value assessments stand up to scrutiny?
That your MI would withstand supervisory challenge?
For many firms, the risk now isn’t poor intent. It’s fragmented oversight. Retrospective sampling. Siloed data. Reactive controls.
In an environment that increasingly expects continuous monitoring and demonstrable outcomes, that simply isn’t enough.
Driving Better Outcomes for Vulnerable Customers
Balancing experience, judgement and accountability in a changing regulatory landscape
To explore what this next phase of Consumer Duty really looks like in practice, we’re hosting a small, invitation-only leadership forum.
📍 Where: The Kimpton Clocktower, Manchester
🗓 When: Tuesday 24th March
⏰ Time: 2:30pm – 5:30pm
This session is designed for leaders across Compliance, Risk, Operations, CX, Digital Transformation and Board-level stakeholders responsible for regulatory outcomes.
It won’t be a slide-heavy seminar. And it won’t be theoretical.
The discussion will focus on the operational reality of 2026–27: what scrutiny now looks like, where firms are being challenged, and what evidence actually matters.
Keynote Speaker: Kevin Still
We’re delighted to welcome Kevin Still, one of the UK’s most respected regulatory advisers.
Kevin brings extensive frontline experience across:
- Consumer Duty
- Vulnerability frameworks
- Debt management
- Data-sharing models
- Inclusive service design
- Cross-sector regulatory change, including BNPL
He’ll share insight into:
- How the FCA’s interpretation of “good customer outcomes” continues to evolve
- Why affordability and communications clarity are climbing further up the agenda
- The growing importance of structured vulnerability models and ISO 22458
- What firms must now be able to evidence – not just implement
One misconception we still encounter is that Consumer Duty is primarily a reporting exercise. It isn’t – It’s an operating model shift.
Why This Matters Now
We’re entering a more assertive phase of supervision.
Across sectors, the FCA is leaning further into:
- Real-world outcomes testing
- Comparative good and poor practice
- Leadership accountability and challenge
- End-to-end journey monitoring for vulnerable customers
- Data quality, governance and oversight
The question regulators are increasingly asking is simple:
If we looked at your customer outcomes today, not last quarter, what would we see?
That requires a different level of visibility.
From Compliance Burden to Operational Advantage
There is, however, an opportunity here.
Some firms are using AI, analytics and automation not just to manage regulatory pressure, but to strengthen performance more broadly, for example:
- Identifying vulnerability earlier in the customer journey
- Monitoring 100% of interactions through automated QA
- Building audit-ready, defensible MI
- Reducing operational risk and inconsistency
- Creating governance models that scale
We’ll also share a live client case study demonstrating measurable impact within a regulated environment – including how firms are building self-funding transformation models with potential ~6-month ROI.
This isn’t about technology for its own sake. It’s about giving leadership teams confidence that outcomes are visible, defensible and continuously monitored.
The Strategic Question for 2026
The firms that will lead over the next 12–24 months are those that can answer one question with confidence:
Can we evidence good customer outcomes – consistently, and at scale?
If that question sits with you, your executive team or your Board, this forum has been designed with you in mind.
To register your interest and request a place, simply click here.
With 25+ years’ experience, IPI combines deep contact centre operational expertise with advanced technology capability to deliver measurable business outcomes. Supporting 4 million customer interactions and 65,000+ agents daily, we help organisations optimise people, process and technology across cloud and on-premise environments. From consultancy and integrations to speech analytics, workforce optimisation, PCI compliance, conversational AI and 24/7 support, IPI provides fully integrated, end-to-end solutions backed by a specialist team focused on client success and continuous innovation.