Consumer Duty is one of the biggest regulatory changes from the FCA we’ve seen for some time. It’s all about how we do business with, and treat our customers throughout their time with us.

What is the Consumer Duty?

The FCA’s Consumer Duty is designed to set higher and clearer standards of consumer protection across financial services and requires firms to put their customers’ needs first.​

It builds on the FCA’s existing principles with the introduction of Principle 12: “a firm must act to deliver good outcomes for retail customers”.  

This principle is supported by three cross-cutting rules and four customer outcomes.

You can find out more about the Consumer Duty itself on the FCA’s Consumer Duty page.

What are the three cross-cutting rules?

Act in good faith towards retail customers

Good faith is defined as “a standard of conduct characterised by honesty, fair and open dealing and acting consistently with the reasonable expectations of retail customers”.​

Avoid causing foreseeable harm to retail customers

Firms are only responsible for addressing harm when it is reasonably foreseeable, defined as whether a prudent firm acting reasonably would be able to predict or expect the ultimately harmful result of their action or omission in connection with the product or service.

Enable and support retail customers to pursue their financial objectives

This includes acting to empower retail customers to make good choices in their interests by creating the right environment. Financial objectives are those connected to the product bought.

How are we responding?

We’ve completed a detailed gap analysis across all products, services, communications and processes to evidence they comply with the new Duty, overseen by our Group executive sponsor:

  • We’ve identified and implemented actions to validate that our products and services are compliant for the 31 July 2023 regulatory deadline.
  • We’ve embedded enduring frameworks and policies across the Legal & General business and culture to ensure our products and services continue to deliver good outcomes for our members.
  • We’ve established action plans for further review and enhancement opportunities.

The four consumer outcomes

While Legal & General has well-established product governance and consumer-focused business arrangements, the Consumer Duty’s four consumer outcomes give us the opportunity to further enhance services across our offering:

Fair value assessments

Our initial fair value assessment results are below, with links to available product summaries:

Table of consumer duty fair value assessments for workplace products
Product Fair value assessment Assessment completed by
PDF file: View - WorkSave Pension Plan PDF size: 687KB Pass Independent Governance Committee
WorkSave Pension Plan - Self Investment Pass Legal & General
PDF file: View - WorkSave Mastertrust PDF size: 395KB Pass Mastertrust Trustees
PDF file: View - WorkSave Buy Out Plan PDF size: 599KB Pass Legal & General
PDF file: View - Group Stakeholder PDF size: 497KB Pass Independent Governance Committee
PDF file: View - Legal & General Personal Pension PDF size: 515KB Pass Legal & General
PDF file: View - WorkSave ISA PDF size: 631KB Pass Legal & General

We will update this information if the outcome of these assessments change, at the earliest opportunity.

If you want to find out more about the way we’re fulfilling our obligations for Consumer Duty, please contact your usual Legal & General representative.