New Aviva research reveals 8 out of 10 advisers say Consumer Duty “feels like a rebranded TCF”

Al Ward

Al Ward, Head of Platform, Aviva
  •  84% agree that it feels like TCF, and only 2% disagree
  •  Only 41% have started preparing
  •  A third (33%) say their firm doesn’t have a Consumer Duty champion

With less than 150 days to go until the launch date of 31st July, new research from Aviva1 shows advisers in relaxed mood about the impending implementation of the Consumer Duty. When asked, over 8 in 10 (84%) agreed with the statement ‘Consumer Duty feels like a rebranded TCF’. 41% said they have started their preparations, with a further 26% saying they had not started but are clear about what they need to do. 17% said they had no concerns.2

Consumer Duty also appeared low down on a list of adviser concerns – ranking 11th out of 14.  By contrast, the main concerns were listed as being inflation (mentioned by 39%), cost of living and the energy crisis (34%) and recession (32%).

One in three said their firm hasn’t appointed a Consumer Duty champion – despite this being a requirement by October 31st last year – casting doubt on whether all obligations are truly appreciated. 

Al Ward, Head of Aviva’s adviser platform, commented : “The Consumer Duty arguably represents the biggest shift in the regulation of financial services in more than a decade. It puts customers at the heart of all our businesses. It would be misguided to see it as a rebranding of TCF. The change is much more fundamental than that. 

“In the words of the FCA, the Consumer Duty “raises the bar”. I agree. It is demanding a cultural shift that truly places the customer at the heart of everything we do. And, crucially, it will measure us against outcomes, not just actions.”

A majority of advisers said that compliance with the Consumer Duty will demand significant changes in their processes. 

In a change that will have implications for platform providers, two-thirds (67%) of advisers said they will be carrying out fresh due diligence on the platforms they use, and 60% thought that their due diligence processes will change. 

Al Ward added : “One of the most important changes that the Consumer Duty will demand of us is that we must provide evidence that we are delivering good outcomes. Whilst it’s encouraging to see a majority of advisers anticipating significant changes in their customer processes, I would invite advisers who feel no change is necessary to reconsider.”

Summary :  ten reasons why the Consumer Duty is not just a rebranded TCF

  1. From fair to good: The Consumer Duty expects us to support ‘good’ outcomes for those we serve, not just ‘fair’ outcomes. The bar is higher.
  2. From actions to outcomes: The Consumer Duty shifts the focus from the actions we are taking to the outcomes we are delivering. We will be judged against these outcomes, not just against our ability to comply with a tick-box list of obligations. 
  3. From words to evidence: The Consumer Duty demands that we evidence how we are supporting good outcomes. Warm words, or even an absence of complaints, will not pass this test. 
  4. From understandable to understood: It remains a requirement that our communications are “fair, clear and not misleading”. The Consumer Duty demands evidence that our communications are understandable and understood by those who receive them. 
  5. For vulnerable customers: Millions of people in the UK will carry vulnerabilities at any one time, be they related to health, life events, financial resilience, or personal capability. The Consumer Duty requires us to give these needs renewed consideration.
  6. For fair value: The Consumer Duty demands that we put in writing why we believe our products and services represent value today, and on an ongoing basis. 
  7. Focus on inaction, as well as action: The Consumer Duty will judge us against actions we may not be taking, as well as those we are, in our responsibility to support good outcomes. 
  8. From one end of the chain to the other: Many in the distribution chain are involved in the delivery of good customer outcomes. The Consumer Duty will not allow us to observe poor practice but say “it’s nothing to do with me”. We’re all in this together.
  9. For the good of those we serve: The FCA is not driving this change for fun. It sees a need to change, and it is using the Consumer Duty to get us there. We can expect the FCA to check we’re all playing our part.
  10. Forever: The Consumer Duty is not a once-and-done exercise. Each business must complete an annual review of its compliance. This one is not going away.


1 Research carried out by Censuswide, 10th – 17th February 2023. 1003 Respondents who work in the financial services sector. Work at a company where wealth or financial advice is the main line of business. Main role: adviser, paraplanner, admin, business principal or business development. Censuswide abides by and employs members of the Market Research Society which is based on the ESOMAR principles.

2 What most closely reflects your views on the introduction of Consumer Duty? Select one.

I have already started preparing – 41%

I have no concerns about Consumer Duty – 17%

I am clear about how to prepare but haven’t yet started – 26%

I am not clear about how to prepare and haven’t started yet – 16%

Other – 0%