Consumer Duty deadline just the starting point when it comes to vulnerability says Jonathan Barrett

by | Jul 31, 2023

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Jonathan Barrett, CEO and Co-Founder at reg tech provider, Comentis,comments on the Consumer Duty deadline which has come into force today.

He said: “Customer vulnerability is the thread that runs through all aspects of the Duty. Now is the time for firms to sit up and make sure they are supporting their vulnerable clients. 

Any business whichoffers credit to pay for their goods and services is going to be affected. Therefore, whether a consumer is buying a car, a pair of glasses or a sofa, if the consumer takes a credit agreement, the firm the consumer purchases from will need to understand if that customer is vulnerable under FCA definition.

This poses a massive challenge for industries that have previously passed on such responsibility to a credit provider. Consumer Duty now needs to be adopted across the whole distribution chain.”

“Development is crucial, when trying to determine where we go next with Consumer Duty. The entire point is that supporting vulnerable customers is something we’ll work on and improve at over time. So, what the FCA wants to see today isn’t necessarily that everyone has every single base undeniably covered. What it really wants is to see that we’re all in the race.”


“The deadline today should be seen as the firing of a starting pistol, marking the beginning of a broader conversation, and understanding on vulnerability. While some might have been looking forward to putting Consumer Duty behind them this summer, the reality is that the topic of vulnerability is here to stay. Over time, as we develop our understanding, the outcomes we deliver for vulnerable customers will start to gradually improve.

But we shouldn’t expect an overnight transformation. We’ll be in escalation for years. As such, and given Consumer Duty is really about continuous improvement, then once this deadline has passed the goal should be for firms to look at the measures they’ve put in place so far and ask how they can go a step further.”

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