Future enforcement actions are likely, especially in areas like later-life income or vehicle finance complaints, where the regulator has shown particular interest.
Separately, the FCA has recently revealed the findings from its review into 20 large insurance firms, highlighting that while there are many examples of good practice, many firms still have some way to go.
It's been confirmed that supervisory tools may be used to ensure the assessed firms are complying.
Firms failing to comply with the duty, whether for open or closed products, can expect little sympathy from the FCA.
Given the additional year provided for compliance with closed products, firms are expected to meet high standards.
If breaches of the duty are identified, the FCA has committed to a proportionate response, prioritising the most serious breaches and acting swiftly.
The past year has demonstrated the FCA's willingness to intervene and investigate, a trend that is likely to continue.
In summary, the first year of the consumer duty has shown the FCA's dedication to enforcement and support.
As the duty extends to closed products, firms must ensure compliance to avoid significant repercussions.
The FCA's active role in regulation is set to intensify, with further actions expected in the coming year.
David Allinson is a partner and Ash Daniells is senior associate at RPC
