Consumer Duty in 2026: Compliance, to Culture, to Customer Advocacy

Consumer Duty has entered a materially different supervisory phase. The FCA is no longer assessing whether firms have compliant frameworks in place – it is asking whether those frameworks are demonstrably improving customer outcomes. This distinction has significant implications for boards.

Square 4 Partners’ 2026 research paper is the most comprehensive independent assessment of where the industry stands. Drawing on surveys from senior leaders across 31 regulated firms representing c.25 million UK consumers, expert review of 48 Consumer Duty board reports, and YouGov‘s Consumer Duty Index – which tracks 8,000 consumers across 200 brands against 14 attributes aligned to the Duty’s core outcomes – it provides boards with a data-driven view of where progress is real, where gaps remain, and where the FCA’s focus is moving next.

What you will find in the report

The five critical areas where board confidence diverges from evidential strength and supervisory expectation, with specific findings and practical actions for each.
A detailed picture of where firms have invested under Consumer Duty, and why the distribution of that investment has resulted in an industry largely able to demonstrate functional compliance but often not able to demonstrate robust outcomes evidence.
Sector-by-sector observations comparing Banking & Lending with Wealth, Life & Pensions, revealing two distinct implementation profiles and the different challenges each faces.
The YouGov Consumer Duty Index data as an external benchmark against which internal confidence can be honestly tested, including which brands are improving, which attributes matter most to customer advocacy, and where the industry’s most significant gaps remain.
Ten questions every board should be able to answer today and the key risks associated with each.