Introduction
The Financial Conduct Authority’s (FCA) Consumer Duty represents one of the most significant regulatory shifts in recent years. It raises expectations for how firms design, distribute, and service financial products. Central to the Duty are its four outcomes, each of which sets clear standards for the relationship between firms and their customers.
Among these, the Consumer Support Outcome focuses on the day-to-day experience customers have when interacting with their financial services providers. It ensures that once a product or service has been purchased, consumers receive the support they need to use it effectively, without unnecessary barriers, and with the confidence that firms are acting in their best interests.
For compliance professionals, understanding and embedding this outcome is essential. It requires more than procedural tweaks; it demands a cultural commitment to treating customers fairly throughout the entire product lifecycle.
The Regulatory Context
The Consumer Duty is Principle 12 of the FCA Handbook: “A firm must act to deliver good outcomes for retail customers.” This principle is supported by three cross-cutting rules—act in good faith, avoid causing foreseeable harm, and enable customers to pursue their financial objectives. The Details of the Consumer Duty regulations can be found in PRIN 2A in the handbook.
The Consumer Support Outcome sits alongside three other outcomes—Products and Services, Price and Value, and Consumer Understanding. Collectively, these outcomes operationalise the Duty, but support is where firms’ policies and culture are most directly tested by customer experience.
The FCA has made clear that poor post-sale service is not acceptable. In its July 2022 Policy Statement (PS22/9), the regulator highlighted practices such as long call waiting times, “sludge practices” that make it hard to switch or cancel products, or opaque complaints processes as inconsistent with the new standard.
Defining the Consumer Support Outcome
The Consumer Support Outcome requires firms to:
- Provide support that meets consumers’ needs throughout the lifecycle of the product or service.
- Avoid unreasonable barriers to consumers who want to act in their own interests, such as switching, claiming, complaining, or cancelling.
- Ensure support is as effective as sales channels. For example, if a firm sells products online, customers should not be forced to use only postal channels for complaints.
- Design support processes that anticipate consumer vulnerabilities, not only reacting to them when they arise.
The principle is simple: once a customer has entered into a relationship with a firm, they should not find themselves trapped, frustrated, or disadvantaged by the firm’s systems or policies.
Why Consumer Support Matters
1. Trust and Confidence
Post-sale support shapes customer trust. A well-designed product can lose all credibility if customers cannot easily use or manage it. Conversely, clear, accessible support builds long-term relationships and strengthens a firm’s reputation.
2. Preventing Foreseeable Harm
Poor support processes can cause financial detriment—for example, if delays prevent a customer from cancelling a product that no longer meets their needs, or if complex claims procedures deter legitimate payouts.
3. Competitive Dynamics
The Duty’s emphasis on support levels the playing field. Firms cannot compete by trapping customers in poor-value products. Instead, they must compete on the quality of outcomes delivered.
4. Vulnerable Customers
The FCA expects firms to integrate the needs of vulnerable customers into every aspect of support. This means considering accessibility (digital, telephone, face-to-face), communication clarity, and sensitivity to life events such as bereavement or ill-health.
Practical Expectations for Firms
Compliance professionals should guide their firms to review and redesign support processes in line with regulatory expectations. Key areas include:
a) Accessibility and Responsiveness
- Support channels must be easy to find and use.
- Call wait times, chatbot functionality, and web forms should be monitored and benchmarked.
- Customers should be able to engage through the same channels in which they purchased.
b) Removing “Sludge Practices”
The FCA has been explicit about avoiding behavioural tricks that discourage customers from acting. Examples include:
- Making it easy to buy online but requiring postal cancellation.
- Requiring multiple calls to complete a single transaction.
- Adding unnecessary steps in complaint processes.
c) Switching and Cancelling Products
Firms must not design processes that lock customers into poor-value arrangements. This includes:
- Transparent, accessible cancellation processes.
- Switching mechanisms that are straightforward, timely, and do not involve hidden costs.
- Proactive reminders where appropriate—for example, when a fixed-term product is approaching expiry.
d) Complaint Handling
Support outcomes overlap with the FCA’s Dispute Resolution: Complaints (DISP) requirements. Under the Duty, firms must consider whether complaints processes genuinely allow customers to voice concerns, and whether the root causes of complaints are being addressed systematically.
e) Supporting Vulnerable Customers
This includes:
- Staff training to recognise vulnerability cues.
- Clear escalation pathways for complex needs.
- Options for non-digital customers, ensuring inclusivity.
Oversight, Monitoring, and MI
Delivering the Consumer Support Outcome requires firms to gather and act on data. Compliance functions should ensure:
- Customer journey mapping: End-to-end mapping of support touchpoints, identifying potential friction.
- Management Information (MI): Regular reporting on call wait times, abandonment rates, complaint volumes, resolution times, and customer satisfaction.
- Outcome testing: Evidence that processes enable customers to achieve their objectives. This could involve mystery shopping, customer surveys, or analysis of switching and cancellation rates.
- Board oversight: Senior managers must be able to demonstrate that they monitor support quality and take corrective action.
Challenges in Implementation
1. Legacy Systems
Many firms rely on outdated technology that hinders seamless support. Compliance professionals should work with operations and IT to prioritise upgrades that remove friction.
2. Outsourcing and Third-Party Arrangements
If support is outsourced, the Duty still applies. Firms must ensure oversight of third-party providers, with SLAs and quality checks aligned to FCA expectations.
3. Balancing Efficiency and Cost
Firms may worry about the costs of expanded support. However, the Duty is clear: efficiency cannot come at the expense of consumer outcomes. Firms should explore automation and digital tools, but not at the cost of accessibility for those less digitally confident.
4. Embedding a Support Culture
Perhaps the greatest challenge is cultural. Firms must move beyond “minimum compliance” thinking and foster a mindset where every support interaction is an opportunity to deliver a good outcome.
Case Examples (Illustrative)
- Positive Practice: A lender enables customers to adjust repayment dates online instantly, reflecting irregular income patterns. Customers are not penalised for making changes, and vulnerable customers can access additional support via a dedicated phone line.
- Poor Practice: An insurer allows customers to purchase cover in minutes online, but requires a lengthy phone call during office hours to cancel. Waiting times are long, and customers are frequently transferred between departments. Under the Duty, this is unacceptable.
The Role of Compliance Professionals
Compliance teams play a critical role in embedding the Consumer Support Outcome:
- Gap Analysis – Assess current support processes against FCA requirements.
- Policy Development – Draft clear policies on switching, cancellation, and complaints that prioritise consumer outcomes.
- Training – Ensure frontline staff understand both regulatory obligations and practical expectations.
- Testing and MI – Establish robust outcome monitoring and evidence frameworks.
- Governance – Support boards and senior managers in demonstrating oversight, ensuring accountability under the Senior Managers and Certification Regime (SM&CR).
Future Considerations
The Consumer Support Outcome is not a one-time compliance project. It is an ongoing expectation that will evolve as technology, consumer behaviour, and market practices change. Areas to watch include:
- Digital engagement: Increasing reliance on chatbots and AI support—firms must ensure these deliver good outcomes, not confusion.
- Data analytics: Using customer behaviour data to predict and pre-empt support needs.
- Cross-border services: Firms operating internationally must balance UK standards with overseas frameworks.
The FCA has also signalled that it will use supervisory and enforcement tools where poor support practices persist. Firms can expect thematic reviews and targeted interventions.
Conclusion
The Consumer Support Outcome under the FCA’s Consumer Duty demands that firms design and deliver support processes that genuinely serve customers’ interests. For compliance professionals, the task is two-fold: ensuring that policies and systems meet regulatory requirements, and fostering a culture where good consumer outcomes are embedded into every interaction.
Success will be measured not by the absence of complaints, but by the presence of positive, friction-free customer experiences. Firms that embrace this approach will not only meet their regulatory obligations but also build trust, loyalty, and long-term value in the marketplace.