Consumer Duty Gap Analysis

While the initial implementation deadline for the FCA’s Consumer Duty has passed, the Regulator continues to highlight shortcomings in how firms are embedding the Duty into their day-to-day operations.

FCA Consumer Duty Checklist 2025

The FCA now expects firms not just to have implemented the Duty, but to demonstrate that it’s embedded across the product life cycle and customer journey. The March 2025 Review of the Consumer Support Outcome reiterates just how important it is to take steps to remedy shortfalls. 

What does ‘good’ look like in 2025’s Consumer Duty? Having policies in place is a given, but now it’s about being able to show that those policies are working in practice.

Firms need to know how to identify gaps in Consumer Duty compliance.

Post implementation Consumer Duty Review

The elements of the Consumer Duty, combined with a deep understanding of the findings from the number of reviews the FCA has published since 2023 means that knowing exactly which audit questions need to be included on the gap analysis is difficult.

From product governance to fair value assessments to customer communications, many firms are still struggling to demonstrate that they’re delivering good outcomes. Our gap analysis template helps to bridge that challenge.

The self-assessment template provides a structured, practical framework for assessing how well your existing policies, processes and documentation align with the FCA’s expectations – pinpointing areas for improvement before they become regulatory issues.

What is a Consumer Duty gap analysis?

The gap analysis template breaks down key areas – such as product approval, fair value, consumer understanding and outcomes monitoring – into clear diagnostic questions. For each one, firms can record their current approach, assess evidence and identify any gaps or weaknesses. Dedicated sections for findings and actions help turn insight into improvement, supporting a cycle of continuous compliance.

How often should firms audit their Consumer Duty Compliance?

The FCA are clear that gap analysis should take place at least once a year, but the overarching expectation is that firms review and monitor their compliance on a regular basis. More frequent reviews are needed where there are material changes to products, customer segments, distribution strategies or emerging risks.

Our template provides a value for money assessment tool for firms to check their own compliance against the FCA’s expectations.

Already completed your gap analysis this year? Our wider Consumer Duty toolkit for regulated firms