The overarching consumer principle, that a firm must act to deliver good outcomes for retail customers, is a reflection of that aim.

The objectives of a retail market where information for consumers is clear, simple and understandable, and consumers themselves are capable and confident are direct precursors to the consumer understanding and product and service design outcomes of the consumer duty.

And the cross-cutting rules to act in good faith, to avoid foreseeable harm and enable and support retail customers to pursue their financial objectives, reflect the goal that firms should be soundly managed, adequately capitalised and treat their customers fairly.

None of these objectives is surprising, none of them should be new to firms doing their best within the industry.  

But the difference is in the way the regulator articulates and supervises them. And the difference this time is that rather than focusing on one sector, the consumer duty cuts across all retail financial services, because the intended result should be the same across the board, and should result in future-proofing the rules for what might lie ahead. 

Alison Gay is senior public affairs consultant at the Lang Cat and a former senior associate at the FCA