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New Consumer Duty - Update 04/23

The Financial Conduct Authority, (FCA), published its policy and final guidance for the new Consumer Duty regulation last July, a year ahead of its introduction. However, AXA UK&I has been working to prepare for the higher consumer protections for some time.

In this initial update, we wanted to share a little about our preparations and to let you know what you can expect from us over the coming months.

As a group that already has the customer at the heart of its business strategy, AXA UK&I welcomes the new Consumer Duty and the increased focus on delivering good outcomes for the customer. We believe that this customer-centric approach will be good for all our businesses and that by working together ahead of its introduction, we can help each other to be ready for Consumer Duty.

The requirements

Consumer Duty requires that businesses take action to deliver ‘good outcomes for customers’ throughout the customer journey by understanding their needs, financial objectives and characteristics, including any vulnerabilities. This applies across the customer journey and specifically for the following four outcomes identified by the FCA: 

  • products and services
  • price and value
  • consumer understanding
  • consumer support

Businesses must also satisfy the ‘cross-cutting rules’ which require them to: act in good faith to deliver good outcomes, help customers to achieve their financial goals and to act to avoid ‘foreseeable harm’ to customers. All firms will also need to show evidence that they are delivering good outcomes for customers in these areas. More information about the new Consumer Duty regulations is available from the FCA.

Work is underway across the business

AXA UK&I has dedicated resources to ensure its readiness for Consumer Duty and has already made good progress in the four outcomes highlighted by the FCA:

  • Products and services – regular product and service reviews will now consider suitability for the needs of all customers on an ongoing basis
  • Price and value – fair value assessments made to assess whether good value is received by all customers including vulnerable customers
  • Consumer understanding – review of our communications and documentation through a customer lens to maximise clarity, accessibility and overall experience 
  • Consumer support – review of FAQs, website content, claims and complaints processes plus service standards to assess appropriateness and accessibility for all customers

Where we have found any shortfalls in customer experience, we are making changes and investing in training and solutions to resolve any issues.

Working together

As a valued partner, AXA is committed to working closely with you, all our broker partners and suppliers across the value chain to meet the July 2023 deadline. We believe that we can achieve a more seamless and superior customer experience by working in tandem to deliver the required good outcomes for all our customers. 

With this goal in mind, we want to ensure you have sufficient time to provide any information we may need. We know that you’re also preparing for the new regulations, so if we do need any specific input from you, we’ll aim to contact you before the end of April with any requests.

In the meantime, please see our FAQs and the detailed information about Consumer Duty that’s available from the Financial Conduct Authority.

David Baker
Chief Risk Officer, AXA UK

Vicki Joshi 
Chief Customer & Brand Officer, AXA UK