Applying proportionality to customer vulnerability under the FCA's Consumer Duty

‘Proportionality does not equal minimalism’

clock • 5 min read

Proportionality is the operational heart of Consumer Duty, writes Andrew Gething

The UK's Financial Conduct Authority (FCA) expects firms to deliver good outcomes for retail customers, as defined within Consumer Duty. Central to the Duty is proportionality – which enables firms' approaches to match the nature of the product or service, characteristics of customers, role in the distribution chain, and size/resources of the firm, all under an objective test of reasonableness. Proportionality does not equal minimalism. It means fit-for-purpose governance, evidence, and controls which are scaled to risk and complexity – not doing less by default. The FCA is looking...

To continue reading this article...

Join Professional Adviser for free

  • Unlimited access to real-time news, industry insights and market intelligence
  • Stay ahead of the curve with spotlights on emerging trends and technologies
  • Receive breaking news stories straight to your inbox in the daily newsletters
  • Make smart business decisions with the latest developments in regulation, investing retirement and protection
  • Members-only access to the editor’s weekly Friday commentary
  • Be the first to hear about our events and awards programmes

Join

 

Already a Professional Adviser member?

Login

More on Regulation

Treasury confirms investigation into potential Budget leak

Treasury confirms investigation into potential Budget leak

Insists banks were not briefed ahead of chancellor's speech

Isabel Baxter
clock 10 November 2026 • 3 min read
Failed financial advice firms tracker

Failed financial advice firms tracker

Firms that the FSCS has confirmed as failed since the start of 2023

Professional Adviser
clock 10 November 2026 • 1 min read
FCA to move Leeds office

FCA to move Leeds office

Signs 2 Wellington Place agreement

Jen Frost
clock 22 October 2026 • 1 min read