The timetable for implementation is aggressive. Whilst the FCA has given firms an additional three months to implement the Consumer Duty as a whole compared with initial expectations (open products and services must comply by 31 July 2023 rather than by the end of April 2023, as originally anticipated) the milestones which must be met before this final deadline are extremely tight. The first deadline is the creation and approval (by the Board, or top-level management) of the firm’s implementation plan by 31 October 2022.

Given the very short timeframes, we have created this short guide to the Consumer Duty implementation plan. This document gives you an overview of the components of a good, comprehensive plan for compliance and encompasses the relevant areas of your business, including governance, marketing and operations.