The FCA Has 11 Open Consumer Duty Investigations. Fair Value Was Never Just About Price.

Published: 15 July 2026

The FCA has confirmed 11 open investigations into potential Consumer Duty breaches, across insurance, pensions, wealth, consumer investments and peer-to-peer lending.

That comes from the regulator's most recent Enforcement Watch. And one line in it deserves to be printed out and stuck above the desk of everyone who signs off a fair value assessment:

“A product or service that doesn’t meet any of the customer’s needs, causes foreseeable harm, or frustrates their objectives, is unlikely to offer fair value whatever the price.”

What most fair value assessments actually show

Most firms can show you a fair value assessment. It will likely have competitor benchmarking, some margin analysis, maybe a RAG rating. All useful, and all necessary.

What is much harder to evidence is whether the product actually does what the customer needs it to do, based on how they really use it. Where does it let them down? Which customers does it not deliver for?

None of that is wrong. It just answers a different question. Benchmarking tells you whether your price sits sensibly in the market. It does not tell you whether the customer who bought the product got what they needed from it.

Those are the questions the FCA's wording points straight at. And in my experience they are rarely answered by a benchmarking table, however well put together.

The customers a product fails

The customers a product fails are often the ones who were never in the research to begin with. The ones with the least financial resilience, competence or confidence to engage.

That is what makes this so hard to get right. If your evidence base is built from the customers who are easiest to reach, it will tell you the product works, because for them it probably does. The people it is failing stay invisible, right up until a regulator, a complaint or a news story makes them visible.

I wrote about a similar gap when the FCA published its review of how firms treat customers in vulnerable circumstances. Designing for the customers at the edges from the start is better design for everyone, and it is far easier than retrofitting it once something has gone wrong.

Why I welcome the scrutiny

The wider numbers in Enforcement Watch are worth noting too: 382 interventions last financial year, and around 30 skilled person reviews that reference the Duty.

It might feel painful for firms right now. But I have to say I welcome this scrutiny from the regulator. Every step like this moves us closer to financial services that truly put customers first, rather than ones that can produce the paperwork to say so.

If I were sitting in a product or proposition team today, I would be asking one simple question of every fair value assessment. Could we show, with real evidence from real customers, that this product meets their needs? Including the customers we find hardest to reach?

Answering that honestly means looking at how customers actually use the product over time, and talking to the people who never make it into a focus group. It is slower than updating a spreadsheet. It is also the only version of the assessment that would stand up if someone outside the firm asked you to prove it.

If you are working out how to evidence that your products genuinely work for all of your customers, book an intro call. It is exactly the kind of problem I love getting stuck into.