The Consumer Duty Code: the shift from compliance to lasting change
By Tyson Matheson
Published: July 31, 2023

In the ever-evolving landscape of financial services, customer needs have always been crucial for successful organisations. With the introduction of the Financial Conduct Authority’s (FCA) Consumer Duty in the UK, the focus on customer care is no longer just a choice, but a necessity. 

The FCA’s Consumer Duty, builds upon the existing regulatory framework to ensure a higher standard of customer care and protection. The aim is to empower consumers to make better decisions while holding financial service providers accountable for delivering positive outcomes and avoiding harm. The Duty encourages a shift from mere compliance to prioritising customer outcomes.

This shift, or as the FCA describes  it, this ‘major shift’ in the UK financial services, represents an opportunity for those organisations who truly believe in this new regulation to differentiate themselves. By adopting a customer-centric approach, and demonstrating genuine commitment to customer care, organisations can position themselves to stand out from the competition, giving them a competitive edge.

Investing in the belief that regulatory requirements can be met in a way that benefits both consumers and the organisation is key.

The Three Pillars of Culture 

The Culture Builders specialise in facilitating organisational change and assisting organisations with aligning their beliefs, behaviours, and processes and systems to achieve their ambitions. The Three Pillars of Culture—what we believe, how we behave, and what we use—are crucial for creating a customer-centric organisation.

What we Believe: The first pillar focuses on what we believe as a team, a business, an organisation. It encompasses the values, purpose and core beliefs (and why). While some organisations may view the Consumer Duty as an added risk and compliance burden, forward-thinking companies see it as an opportunity to build customer loyalty and retention.

How we Behave: The second pillar examines how we behave as an organisation. It encompasses the language we use, the actions we take, and the behaviours we exhibit. Ensuring that behaviours align with the organisation’s beliefs is crucial for initiating and sustaining a culture shift towards customer-centricity. The Culture Builders specialise in facilitating change at both individual and team levels, helping organisations create new habits that support the desired behaviours.

What we Use: The third pillar focuses on the systems, structures, processes, technologies and environments that enable the beliefs and behaviours. While tools, support systems and infrastructure are important, they should not be the starting point for implementing change. It is crucial that beliefs and behaviours are aligned before implementing any supporting systems. 

All three pillars—What we Believe, How we Behave, and What we Use—must work in harmony to create a culture where more individuals are invested (‘Investors’) in the long-term success of the organisation rather than just fulfilling their assigned duties (‘Savers’). Investors are those  individuals who see the Consumer Duty as a chance to deliver positive customer outcomes rather than a risk to be mitigated. By identifying and leveraging the investors within your organisation, you can build the belief that compliance with the Consumer Duty is not just a requirement, but an opportunity to stand out.

Auditing the required shifts

The Culture Builders often start any culture or change transformation work with a thorough audit that explores the Three Pillars in great detail. By conducting one-on-one interviews with key stakeholders and senior management, as well as facilitating interactive insight sessions with team members from across the organisation, The Culture Builders can assess the shifts required to meet the organisation’s ambitions, including those mandated by the Consumer Duty. 

In addition, The Culture Builders have developed Kachow, a unique app that captures team members’ sentiments no matter their location, over a period of time ensuring a deep understanding of beliefs and the necessary shifts required to meet organisational ambitions. 

From this point, a set of action plans is developed to not only identify the necessary shifts but also outline the actions required to embed and sustain these changes, ensuring a long-lasting impact.


The FCA’s Consumer Duty marks a significant shift in the regulatory landscape of financial services in the UK. By prioritising positive customer outcomes, organisations have the opportunity to differentiate themselves, build trust, and enhance customer loyalty. Embracing the Consumer Duty will require a commitment to cultural change  and a focus on delivering value, clear communication, and support to customers. 

Whether your goal is to foster a high-performance culture, shift beliefs and behaviours to become more customer-centric, or implement lasting change, The Culture Builders are dedicated partners in helping financial services organisations navigate this transition successfully. By aligning beliefs, behaviours, and systems, organisations can position themselves as leaders in customer care and thrive in the ever-evolving financial services industry.