Following the introduction of the Consumer Duty in July last year, the FCA is closely monitoring how firms are performing and what improvements customers and the industry are seeing for existing and open products.

The deadline for implementation of the duty for closed products is July 31, 2024. The Council has commissioned Deloitte to produce guidance to support member firms ahead of the July deadline.

For firms, the implementation of the duty for closed products is a chance to show that they have learned the lessons from last year, and that they have been able to review and reflect on how suitable their original plans for implementation were.

Closed products – where there are existing contracts with retail customers entered into before July 31, 2023; and
which is not marketed or distributed to retail customers (including by way of renewal) on or after July 31, 2023.