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Following criticism from the Treasury Select Committee, experts say the UK Financial Conduct Authority’s (FCA) decision to remove the requirement for firms to have a board-level Consumer Duty champion will have only a limited impact.
The FCA opted to remove the compliance requirement for supervised firms to have a Consumer Duty champion on their boards after being pushed by the government, which was looking for ways to improve the UK economy’s growth prospects.
In a January 2025 letter to the Prime Minister, FCA CEO Nikhil Rathi, who has just been confirmed for a second term in the position, said that in a bid to reduce the “regulatory burden”, the supervisor will “remove the need for a Consumer Duty Board Champion now the duty is in effect”.
However, the reaction to the announcement has so far been less than positive.
For example, as covered by Vixio, Labour member of Parliament Dame Siobhain McDonagh suggested in a Treasury Select Committee hearing that the regulator appears to be “involved in a bit of virtue signalling”.
No major change
Max Savoie, a partner at Sidley Austin, told Vixio that firms subject to the Consumer Duty will still be expected to maintain robust governance, with clear board oversight and senior individuals taking responsibility for applying Consumer Duty obligations.
“The idea of a board-level champion is just one element within a broader set of obligations, alongside requirements around fair value and customer care,” he said.
Omar Salem, a partner at Fox Williams, agreed, telling Vixio: “Getting rid of the Consumer Duty champion role was largely performative.”
He added that the “same could be said for a lot of the points being made by the FCA at the moment with the push for growth”.
“In some ways, it doesn’t really matter. There was no harm either way, but also no significant impact,” he said.
“We’re seeing a flood of initiatives without much focus on where time and energy can actually make a difference.”
According to Salem, this compliance requirement was relatively easy.
“Everyone already knew it was a priority for the FCA. It was more about signalling the importance of board-level leadership than driving meaningful change. Whatever impact it had was fairly limited.”
The benefits of the move
On a more positive note, Savoie did point out that the removal of the requirement for a board-level champion may give firms more options in terms of how they comply with the Consumer Duty.
For example, if a firm is struggling to identify a specific individual to act as Consumer Duty champion, it could take a more distributed approach, sharing the responsibilities across several roles.
“That’s not necessarily a bad thing — the duty is supposed to be embedded in a firm’s culture,” said Savoie.
“Even if a firm does appoint a champion, that doesn’t absolve it of wider responsibility,” he added.
“The concern, or potential downside, is that some firms may interpret this shift as a sign that the FCA is stepping back from governance, or showing less interest in oversight. But I don’t believe that’s the intention."
Consumer Duty remains a priority
Savoie said that compliance with the Consumer Duty will continue to be of paramount importance for firms, and that they should not take the removal of the champion requirement as a backing down on enforcement or a significant loosening of the rules.
“The FCA made it quite clear in its Dear CEO letter that Consumer Duty compliance remains a priority for the payments sector,” he said. “It highlighted specific areas where it's focusing its attention, including FX rate disclosures.
“The main takeaway is that while this isn’t a massive change, it could give some firms a bit more flexibility."
