Consumer Duty and post-sale support in protection
The Duty does not stop at the sale. Firms need to show customers understand what they bought and can get help throughout the life of the product.
The Duty in brief
The Consumer Duty, set out in PRIN 2A of the FCA Handbook, requires firms to act to deliver good outcomes for retail customers. It came into force for open products on 31 July 2023 and for closed books on 31 July 2024. The FCA's finalised guidance, FG22/5, explains how firms might comply.
The four outcomes
The Duty is organised around products and services, price and value, consumer understanding and consumer support. For protection distributors the last two are particularly relevant after the sale: customers need to understand their cover, and support should meet their needs throughout the life of the product.
What this means after the sale
Firms should not assume understanding just because documents were sent. They should consider whether customers know what they are covered for, how to claim and where to get help, and whether anything has gone wrong in the transition from application to policy. They should also make it as easy to get help or make changes as it was to buy.
Evidence, not assertion
The FCA expects firms to monitor outcomes and act on what they find. Records of customers confirming their cover, raising issues and having those issues resolved are direct evidence of support in practice. So is data showing which groups of customers are less clear about their cover, and what the firm did about it.
Vulnerable customers
Firms must take particular care of customers with characteristics of vulnerability. Giving customers a choice of channel, plain-language journeys and an easy route to a person helps, as does flagging responses that suggest a customer may need extra support.
Doing it proportionately
Phoning every customer after every sale is rarely realistic. Structured digital engagement lets a firm reach the whole book consistently, capture evidence of understanding and route the customers who need help to a person. It supports the Duty without replacing the human relationship.
The cross-cutting rules
Alongside the four outcomes, the Duty includes three cross-cutting rules: act in good faith, avoid causing foreseeable harm, and enable and support customers to pursue their financial objectives. After a protection sale, foreseeable harm might include a customer paying for two policies when one should have been cancelled, cover lapsing because a failed payment was never followed up, or a claim being harder than necessary because the customer does not know how to make one.
Making support as easy as the sale
FG22/5 makes the point that it should be as easy to get support, make changes or cancel as it was to buy. For distributors, that means clear routes for customers to ask questions, update details or raise concerns after the sale, without having to wait on hold or chase a call-back. Digital journeys can provide this at any time of day, with a route to a person for anything that needs one.
Board reporting
Firms must produce an annual board report assessing whether they are delivering good outcomes. For protection distributors, useful post-sale measures include the proportion of new customers who confirmed their cover, the number and type of issues raised and resolved, time to resolution, cancellation rates by cohort and reason, and outcomes for customers with characteristics of vulnerability.
Distribution chain responsibilities
The Duty applies across the distribution chain. Distributors and insurers each have responsibilities, and information should flow between them. Post-sale data, such as recurring issues with documents or policy details from a particular insurer, is useful for insurers' own product governance as well as for the distributor's monitoring.
A practical first step
If you do one thing, make sure every new customer is asked, soon after their policy starts, whether they have what they need and understand their cover. Record the answer, act on the issues and report the results. It is simple, proportionate and directly linked to the outcomes the Duty describes.
Common gaps
Reviews of Consumer Duty implementation have tended to find similar gaps: firms relying on documents being sent rather than understood, limited monitoring of outcomes after the sale, and board reports that describe processes rather than results. Post-sale engagement addresses each of these directly, because it creates a record of what customers understood, what went wrong and what was done about it.
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FCA: PRIN 2A, the Consumer Duty
FCA: FG22/5, final guidance on the Consumer Duty
FCA: Consumer Duty publications and resources
Adviser.ai figures are drawn from anonymised client data and are illustrative. Results vary by firm, product and implementation.
Last updated 27 October 2026