Consumer Duty in 2025: By 2025, Consumer Duty was established across open and closed retail products.
The focus was no longer whether firms had introduced the required policies. The more important question was whether those policies improved real client outcomes.
For mortgage advisers and Connect appointed representatives, this placed greater importance on outcome monitoring, vulnerability, fair value and root cause analysis.
The principle was practical. A firm should not wait for individual cases to fail before looking for a pattern.
At a Glance
Consumer Duty in 2025 focused on embedding, testing and improvement.
Mortgage advisers needed to use file findings, client feedback, complaints and business data to identify where outcomes could be stronger.
For Connect ARs, this meant treating compliance information as a learning tool rather than an administrative record.
From File Compliance to Outcome Monitoring
A file can contain every required document and still raise questions about the client’s outcome.
For example, the documentation may be complete, but the client may not have understood:
- Why a product was recommended
- How payments could change
- What fees applied
- Which risks remained
- What would happen after the fixed period
- Why another option was unsuitable
Outcome monitoring looks beyond whether a process was followed.
It considers whether the process worked.
What Should Advisers Monitor?
An individual adviser may not control the network’s full data strategy. However, each adviser contributes information that helps the firm assess outcomes.
Useful evidence may include:
- File review findings
- Client complaints
- Product cancellations
- Application delays
- Lender declines
- Advice fees
- Client feedback
- Vulnerability records
- Missed review opportunities
- Repeated communication questions
- Cases that required remedial work
The information should be reviewed for patterns.
One delayed application may have a simple explanation. Repeated delays at the same stage may indicate a wider process problem.
Root Cause Analysis
Root cause analysis asks why an issue occurred.
It should go further than correcting one file.
Suppose several clients say they did not understand an adviser fee. The immediate response may be to explain the fee again.
The deeper review should consider:
- Where the fee was first disclosed
- Whether the wording was clear
- Whether it was discussed verbally
- Whether the client confirmed understanding
- Whether different advisers used different explanations
- Whether documents displayed the fee consistently
The purpose is to prevent the same issue from affecting future clients.
A correction resolves one case. Root cause analysis can improve the whole process.
Consumer Vulnerability in 2025
Client vulnerability remained a significant Consumer Duty consideration.
A client may be vulnerable because of health, life events, financial resilience or capability. Vulnerability may also be temporary.
Mortgage advisers may encounter vulnerability when a client experiences:
- Bereavement
- Relationship breakdown
- Redundancy
- Serious illness
- Reduced income
- Problem debt
- Low financial confidence
- Language or communication barriers
- Caring responsibilities
- A major change in living arrangements
The adviser should not diagnose the client.
They should identify whether the client may need a different form of support.
What Reasonable Support Can Look Like
Support should be based on the client’s circumstances.
It may include:
- Allowing more time
- Dividing information into smaller stages
- Using a preferred communication method
- Providing a written summary
- Including a trusted person with permission
- Checking understanding more than once
- Changing the appointment time
- Referring the client to another service
- Recording agreed adjustments
The record should explain what was identified and how the advice process responded.
Sensitive information should only be recorded where it is relevant and handled appropriately.
Fair Value and Mortgage Advice
Fair value does not always mean the lowest price.
An advice service may include research, complex case placement, ongoing communication and support through the application.
The adviser should still be able to explain why the total cost is reasonable for the service provided.
A fair value review may consider:
- The scope of the service
- Adviser fees
- Commission received
- Case complexity
- Work completed
- Expected client benefits
- Service limitations
- Whether different client groups receive comparable value
The assessment should be honest.
A higher fee may be reasonable for a complex case. However, complexity should not be used as a general explanation where the work does not support it.
For further information, advisers can review the FCA’s Consumer Duty information for firms.
Consumer Support After the Recommendation
Consumer Duty does not stop when the recommendation is issued.
Clients may require support while their application is being processed or after the mortgage completes.
Advisers should make clear:
- Who will provide updates
- How the client can ask questions
- What happens if circumstances change
- When new documents may be required
- Whether post-completion reviews are available
- Who to contact if a problem arises
A client should not find it much harder to receive support than it was to begin the application.
Learning From Complaints
A complaint is not only a problem to resolve.
It is also information about the client journey.
Firms should consider whether the cause could affect other clients.
Questions may include:
- Did the client receive unclear information?
- Was there an avoidable delay?
- Was a support need missed?
- Did the adviser make an unsupported assumption?
- Was a fee explained too late?
- Did the process create an unreasonable barrier?
- Does another client require remedial action?
Advisers should report complaints and concerns promptly.
Incomplete reporting can prevent the network from seeing a wider pattern.
How Connect Supports Continuous Improvement
Connect Network can use file reviews, compliance findings and adviser feedback to improve its support framework.
For appointed representatives, this may include:
- Targeted training
- Updated guidance
- File review feedback
- Advice process templates
- Compliance communications
- Specialist case discussions
- Business monitoring
- Professional development
Learn more about mortgage network compliance support.
The purpose is not to create more paperwork without reason.
It is to help advisers identify risk earlier and explain their decisions more clearly.
Adviser Visibility and Consumer Understanding
Consumer Duty begins before the first advice meeting.
Online information should help a prospective client understand who provides the service and what they may receive.
Complete adviser profiles can support informed choice by explaining:
- Adviser location
- Relevant areas of expertise
- Languages spoken
- Appointment options
- Regulated permissions
- Contact details
Connect ARs can use the Connect Experts adviser directory to present this information in a consistent format.
A directory profile should be accurate and current. It should not promise services that the adviser cannot provide.
What Connect ARs Should Take From 2025
The main lesson from 2025 was that data should lead to improvement.
A firm should be able to explain:
- What it measured
- Why it measured it
- What the results showed
- Which risks were found
- What changed as a result
- Whether the change worked
For advisers, this means responding constructively to file reviews, complaints and client feedback.
Consumer Duty is strongest when evidence changes behaviour.
A completed spreadsheet records the past. A useful decision improves what happens next.
Frequently Asked Questions
What is Consumer Duty outcome monitoring?
It is the process of assessing whether clients receive the intended outcomes across products, value, understanding and support.
Is a compliant file enough?
Not always. Firms should also consider whether the client understood the advice and received appropriate support.
What is root cause analysis?
It examines why a problem occurred and whether the same cause could affect other clients.
Does vulnerability always need to be permanent?
No. Vulnerability may be temporary, situational or change during the mortgage journey.
Does fair value mean offering the cheapest service?
No. It means there is a reasonable relationship between the service, its cost and the benefits received.