Consumer Duty and its impact on the retail motor sector 

The Financial Conduct Authority's (FCA) new Consumer Duty regulation aims to create a higher standard of care for consumers. What does this mean to UK motor retailers and repairers?

Most dealerships distribute financial products to enhance vehicle sales. Under the new regulation, dealerships must evidence their Consumer Duty actions to ensure they meet the FCA's higher standards and expectations.

However, with fewer vehicle sales and changes in customer behaviour, Consumer Duty is an opportunity for automotive firms to build loyalty and drive profitability by exceeding regulatory requirements.

Putting the customers' needs first is the cornerstone of the Consumer Duty Principle. Here we look at what it means for those in the retail motor sector, whether online or in the showroom.

What is the FCA's Consumer Duty?

The regulation comprises three key components:

Firstly, an overarching Consumer Duty Principle sets a higher standard of care that the FCA expect companies to adhere to, evidencing their actions to deliver good client outcomes.

Secondly, the FCA has defined three cross-cutting rules that set out the standards of conduct expected across all areas of a firm's retail financial services activities, including:

  1. Act in good faith.
  2. Avoid foreseeable harm.
  3. Enable and support them to pursue their financial objectives.

Third and finally, four outcomes include rules and guidance across critical elements of the firm-customer relationship.

  1. Products and services.
  2. Price and value.
  3. Consumer understanding.
  4. Consumer support.

How will the Consumer Duty impact the retail motor sector?

As a distributor of financial products, such as automotive finance and Guaranteed Asset Protection (GAP) insurance, dealerships must demonstrate how they act to deliver good customer outcomes.

The FCA will expect dealerships to:

  • Have a robust Consumer Duty implementation plan outlining their steps to meet their obligations.
  • Show information they get from manufacturers on financial products they distribute, enabling them to meet their obligations, specifically on products, services, price, and value.
  • Demonstrate implementation and evidence of processes to meet the Duty for all products and services currently offered.

New regulations, production delays, supply chain disruption, market liquidity, fewer car sales and changes in customer behaviour are significant challenges affecting the automotive industry.

The changing landscape of dealerships means that improving retail profitability has never been more challenging. Market uncertainty makes it essential to manage customer expectations.

Consumer Duty is an opportunity for dealerships to build loyalty and drive profitability by exceeding their obligations. But to achieve this, dealerships must deliver a fantastic customer experience (CX).

In what way does the products and service outcome apply?

Automotive dealerships must ensure their vehicles are safe, reliable, and fit for their intended purpose. Here are examples:

Disclosure: Dealerships must disclose information about the vehicles they sell, including any known defects, accidents, or other issues that may affect their safety or performance.

Product liability: Automotive dealerships can be held liable for any injuries or damages resulting from defective vehicles they sell, including defects in their design, manufacture, or assembly.

Advertising: Car dealerships must ensure that their advertising is truthful and not misleading. They cannot make false or exaggerated claims about the safety or performance of their vehicles.

Consumer protection laws: Dealerships are subject to a range of consumer protection laws, including laws that prohibit unfair or deceptive practices, that require specific and conspicuous disclosures, and that provide consumers with certain rights and remedies.

Warranty: Automotive dealerships must honour any promises they offer on the vehicles they sell, ensuring consumers can have any covered repairs or services performed promptly and effectively.

In what way does the price and value outcome apply?

Traditionally, a car dealership will offer automotive finance as part of the vehicle sale. The uptake of vehicle ownership links directly to finance availability.

Figures from the Finance and Leasing Association show that consumer car finance increased by 9% by value and 3% by volume in 2022.

The price and value outcome requires that dealerships provide consumers with fair and transparent pricing and ensure that the product or service's value is commensurate with the price paid. Here are examples:

Pricing transparency: Car dealerships must provide consumers with clear and transparent pricing information, including the base price of the vehicle, any additional fees or charges, and the car's total cost. They must also be upfront about any discounts, promotions, or financing options available to consumers.

Fair pricing: Dealerships must ensure that the prices they charge for their vehicles are fair and reasonable. They cannot exploit consumers by charging inflated prices or engaging in price gouging. Fees charged must align with industry standards and not engage in discriminatory pricing practices.

Value for money: Automotive dealerships must ensure that their vehicles provide consumers with fair value. Vehicles must be reliable, safe, and fit for their intended purpose. Dealers must provide consumers with the features and benefits they expect based on the price paid.

Financing: Car dealerships must ensure that their financing options are fair and transparent and do not charge excessive interest rates or fees. They must provide consumers with clear information about their financing options, including the total cost of financing and the terms and conditions of the loan.

In what way does the consumer outstanding outcome apply?

The consumer understanding outcome requires firms to ensure that consumers understand the products and services they are buying, including the risks and benefits. Here are examples:

Providing clear information: Dealerships must provide consumers with clear and understandable information about the vehicles they are selling, including their features, specifications, and any associated risks. They must provide information about safety ratings, fuel efficiency, emissions, and other vital factors that may affect the value and performance of the vehicle.

Explaining financing options: Car dealerships must provide clear and transparent information about their financing options, including the total cost of financing, the interest rate, and any associated fees. They should also explain any risks or downsides related to financing options, such as balloon payments or variable interest rates.

Helping consumers make informed decisions: Dealerships must help consumers make informed decisions. They must provide guidance and advice about the vehicles based on the consumer's needs, budget, and other relevant factors to achieve this. Dealerships must also include recommendations on specific models or features and information about alternative options, such as leasing or buying used.

Providing ongoing support: Car dealerships must offer ongoing support to consumers after they purchase. Support could include guidance on maintenance and repairs and assistance with any warranty claims or other issues that may arise.

In what way does the consumer support outcome apply?

The consumer support outcome requires firms to provide ongoing support to consumers after purchasing products or services. Here are examples:

Assisting with warranties: Dealerships must provide ongoing support to consumers after purchasing a vehicle, including assistance with any warranty claims or other issues that may arise. They must provide evidence that consumers understand the terms and conditions of their warranty and provide support with any repairs or maintenance covered.

Offering maintenance and repair services: Automotive dealerships must provide maintenance and repair services to consumers through their service departments or partnerships with third-party service providers. They must guide routine maintenance and repairs and offer repairs for more complex issues.

Guidance on financing: Car dealerships must provide ongoing support to consumers who have financed their purchase, including advice on payments, interest rates, and any other aspects of their loan agreement. They must also help with refinancing or renegotiating the loan terms, if necessary.

Offering assistance with trade-ins and upgrades: Car dealerships must support consumers looking to trade in their vehicle or upgrade to a newer model. They must guide the trade-in process and offer competitive pricing for the consumer's vehicle.

How can dealerships achieve a higher standard of care?

The FCA will review Consumer Duty plans to understand a dealership's approach to embedding the regulation within the business. Putting the customer at the heart of the business means ensuring every procedure, process, and system keeps the consumer in mind.

Consumer Duty obligations require service providers to consider the customer's needs at every lifecycle. Therefore, customer journey mapping is the ideal way to see the business through its customers' eyes.

At insight6, we have the expertise to provide customer journey mapping, a valuable tool as dealerships begin to evidence their customer experience.

Feedback is essential to achieving a higher standard of care. Real-time, actionable feedback helps to deliver positive customer outcomes and will support evidencing Duty actions.

Often firms buy off-the-shelf systems to carry out their customer feedback. Unfortunately, some car dealerships can damage the customer experience (CX) in pursuit of feedback. An independent third-party assessment is best to achieve an accurate view.

Instant insight is our total feedback solution, enabling you to gather real-time feedback from your customers and team. We can work with you to understand your desired outcome and agree on the objectives. Doing so lets us explain how we plan to measure and report against these goals.

How can car dealerships increase loyalty and drive profitability?

The new regulation is an opportunity to deliver a consistently positive customer experience which will add value to dealerships over the long term. To improve the customer experience (CX), you must put the customer at the heart of the business.

The insight6 guide to Consumer Duty: Putting clients at the heart of business will show you how to build loyalty and drive profitability by exceeding your regulatory requirements with a CX approach.

Positive customer experiences make your customers happy and increase the likelihood of returning, leaving a positive online review, or recommending you to others. Car dealerships need a robust CX strategy.

By partnering with us, we can help you demonstrate and evidence your commitment to experience excellence, precisely how to deliver good customer outcomes and give you compliance confidence.

Our three-step process will help automotive dealerships address the Duty requirements across all four outcomes and give compliance confidence.

At insight6, we have developed some of the most advanced CX programmes. Our bespoke feedback tools, trained researchers and CX solutions have earned us a reputation as the partner of choice for many of the UK's largest automotive dealerships.

As well as working with hundreds of clients UK-wide, we are the only company with a network of CX Directors to support car dealerships locally. Get in touch today to see how we can transform yours.

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How to evidence consumer duty actions and ensure good consumer outcomes

The Financial Conduct Authority’s (FCA) new Consumer Duty regulation is one of the most significant shifts in UK financial services. The intention for companies to put the client's needs first is admirable, but evidencing actions can be a challenge. 

Putting the client at the heart of the business means ensuring every procedure, process, and system keeps the consumer in mind.  

Financial services firms that must be Consumer Duty compliant, but also want to build loyalty and drive profitability, will need a customer experience (CX) solution. Keeping clients is critical in a competitive environment, so a CX strategy is imperative.  

At insight6, our unique and tailored CX solutions and local specialists transform businesses, earning us a reputation as the partner of choice for many financial services firms. Here we share our three-step CX process to the FCA’s Consumer Duty.

What is the new Consumer Duty? 

Consumer Duty is a regulation introduced by the UK financial regulatory body, the Financial Conduct Authority (FCA).  

There are three parts to Consumer Duty: 

  1. Consumer Duty Principle. A higher consumer protection standard for financial firms. 
  2. Cross-cutting rules. Overarching requirements for setting standards of conduct across all areas of a firm's retail financial services activities. 
  3. The consumer outcomes. A detailed set of requirements applies to four client/customer relationship aspects. 

Putting the client's needs first is the cornerstone of Consumer Duty Principle – it is a good business practice to ensure good consumer outcomes. So, a properly considered and managed customer experience (CX) programme is critical to regulatory success. 

What are the three cross-cutting rules of Consumer Duty? 

 The Duty's three cross-cutting rules set the overarching requirements setting standards of conduct expected across all areas of a firm's retail financial services activities. 

  1. Act in good faith 
  2. Avoid causing foreseeable harm. 
  3. Enable and support customers to pursue their financial objectives.  

What are the four outcomes of Consumer Duty? 

The Four Outcomes cover critical elements of the firm-customer relationship.  

Specifically, the outcomes require firms to ensure that products and services meet client's needs, that pricing is transparent and offers fair value, and that consumers receive communications to understand and get the support they need. 

  1. Products and services outcome. To ensure fit for purpose. 
  2. Price and value outcome. A focus on transparent pricing and fair value. 
  3. Consumer understanding outcome. To enable clients to make informed decisions. 
  4. Consumer support outcome - good quality support and after-sales care. 

Obtaining client feedback is one of the best ways to evidence your actions towards achieving the Four Outcomes. A robust CX strategy will provide you with insights to improve good consumer outcomes, become Consumer Duty compliant and increase your profits. 

Managing feedback is a crucial part of the CX process, so working with the right partner is paramount to evidencing your Consumer Duty actions. At insight6, our unique icx6 philosophy and partnership model is your guarantee of great service.

When does Consumer Duty take effect? 

There are five milestones to prepare for the new milestones to take effect.  

The FCA released the final guidance on its consumer duty at the end of July 2022. By October 2022, firms had to agree on their implementation plans. Now, firms must work towards achieving milestone three - completing reviews to meet the outcome rules. 

Duty rules start for available products and services on 31 July 2023, then a year later (31 July 2024) for closed products and services. 

You can view the detailed Consumer Duty timeline online. 

What does Consumer Duty mean for the industry?  

Consumer Duty aims to ensure financial firms take responsibility for operating in their client's best interests and treating them fairly. Financial services firms must look beyond compliance to strategy, data and technology to achieve this. 

To evidence their intentions and actions, firms must be client-centric, consistently reviewing practices and asking for feedback across multiple client engagement touchpoints.   

Consumer Duty is an opportunity to deliver a consistently positive client experience which will add real value to the business over the long term. Investing in a robust customer experience (CX) strategy and tailored solutions will put clients at the heart of the business to ensure good client outcomes whilst building loyalty and driving profitability. 

How to evidence Consumer Duty actions and ensure good outcomes 

Putting the client at the heart of the business means ensuring every procedure, process, and system keeps the consumer in mind. Repeatedly reviewing your business and asking your clients and staff for feedback is critical to proving your actions and becoming compliant.  

At insight6, we work with hundreds of happy clients to put the customer first by building a robust CX strategy to improve the customer experience, build loyalty and drive profitability.  

Our three-step CX process to the FCA’s Consumer Duty will help financial firms evidence their actions and ensure good client outcomes. 

insight6 three-step CX plan to Consumer Duty compliance: 

  1. Putting the client at the heart of the business - the customer journey 
  2. Embedding a client engagement programme - regular customer feedback  
  3. Creating a client-centric culture - training, mentoring, and coaching 

How to put the client at the heart of the business 

We recommend you map the client journey alongside where the business currently sits within the new Consumer Duty requirements.  

You can map the client journey internally, but using an independent facilitator will ensure an accurate picture of your business through your client's eyes. 

Mapping the client journey will enable you to look at multiple consumer touchpoints. From how your teams handle initial enquiries, respond to clients, provides information requested, or respond to messages right through to effective complaint management and encouraging client referrals - the list of things you can review is endless.   

How to embed a client engagement programme 

To embed an effective client engagement programme, you need data and feedback. 

Ideally, data and feedback based on actual customer experience reviews (also known as mystery shopping) as well as other client feedback 

The FCA will likely want to see client trust, confidence and fair value measured as a bare minimum. Still, Consumer Duty is an opportunity to delve deeper into your client’s experience and achieve better results. 

Consistently asking for, reviewing, and acting on feedback will help evidence your Consumer Duty actions to become compliant. Importantly, embedding a client engagement programme will enable good customer outcomes by helping to improve your overall client experience. 

The Duty emphasises supporting clients to make informed decisions on financial products and services, especially safeguarding vulnerable clients.  

Careful consideration of the client journey and evaluation of every touchpoint with the client will enable a firm to evidence how it regularly tracks any changes to a client's situation and detail fallback plans.  

How to create a client-centric culture 

Creating a client-centric culture is imperative to become Consumer Duty compliant.  

Your employees play a pivotal role in delivering your product or service. Workplace culture is part of everything an organisation says and does, making it difficult to transform even when necessary.  

In the current climate, the working environment is constantly changing and challenging to predict. Plus, the new regulation will likely bring new challenges for your team. It's essential to know the impact it's having on your staff.  

Measuring employee engagement and giving the proper support, training, mentoring, and coaching will be critical to ensure your firm and staff meet Consumer Duty requirements. 

Creating a great working culture within your business ensures that your team can give the best experience for your clients. You need access to fast, actionable feedback from your team that makes them feel highly motivated, engaged and respected.  

Key takeaway on Consumer Duty 

Putting the client's needs first is the cornerstone of Consumer Duty. Financial services firms must evidence their actions and ensure good consumer outcomes to gain regulatory approval. Investing in a robust CX strategy will put clients at the heart of the business, enabling you to improve the customer experience, build loyalty and drive profitability. 

If you need help or advice navigating the new Consumer Duty regulation, get in touch today to find your local customer experience specialist and to arrange a no-obligation chat.  

Like what you’ve read? Sign up to the insight6 newsletter to keep up to date with everything you need to know to improve your customer experience.   

The best ways to make your customer experience shine this holiday season 

A gloomy economic outlook has left many with a distinct lack of holiday cheer. However, now is the time for businesses to pull on their jolly pants and deliver a more joyful customer experience.  

Squeezed incomes mean shoppers will rein in their spending, and consumers will look for better service deals. Don’t let margins be the Grinch that steals your Christmas.  

The customer experience is fast becoming the main reason people choose to buy from a business. Yet, research shows that 80% of companies say they deliver a ‘superior’ customer service, while only 8% of customers thought the same about those companies. 

We believe the customer experience is everything. How you make people feel will be this season’s smartest strategy to win and keep customers. Christmas isn’t a season, it’s a feeling.  

At insight6, we partner with hundreds of happy clients to improve the customer experience and transform businesses. Here, we share tips to make your customer experience shine this holiday season. 

Six simple ways to sprinkle some customer experience magic

1. Engage and empower your team 

Your employees play a pivotal role in service delivery. Have a clear service plan and communicate it regularly to your team. 

The festive period can be a stressful and busy time. Understand the work pressure that squeezed deadlines, increased footfall and sales can bring on service delivery. Regularly check in on staff wellbeing.

80% of the UK’s workforce work in customer-facing roles. Sadly, research shows that more than half of customer-facing staff have faced abuse from customers since the start of the pandemic. 

Consider what to do when things go wrong. Empower your staff to act and fix problems and handle complaints cheerfully.  

Disengaged staff do not go the extra mile for your customers. Think about the best ways to recognise and reward great service.  

2. Manage customer expectations  

Christmas is a busy time of year for everyone. Encourage frontline staff to be honest to avoid over promising and under delivering.  

Handling new enquiries effectively can make or break a sale. Understanding your customer journey will help you to engage staff, prepare for the unexpected and polish your frontline service. 

Customers may look for alternative ways to get in touch or complain, such as webchats, email and social media during busy periods. Make sure your staff and outsourced service providers are ready.  

Delays can't be helped but you can turn a potentially frustrating experience into a pleasant one. Make hanging on the telephone joyful, switch traditional hold music to upbeat festive favourites.  

After a busy year, everyone looks forward to a break. Be clear about your opening hours, ability to deliver and shipping deadlines. Don’t forget to put your out-of-office on and include a seasonal sentiment. 

 3. Create WOW moments 

WOW moments are memorable experiences that you create for your customers by exceeding their expectations. Delighting your customers will help turn them into loyal fans and keep them coming back. 

First, do what you say you are going to do. If your service delivery falls short, you can still WOW customers when they complain. Empower staff to tackle issues, say sorry and offer suitable compensation. 

Christmas is the season of giving. Offer something your customers didn’t know they needed. Look for ways to WOW with an upsell or make small gestures that show you pay attention.


  • Send handwritten Christmas cards. 
  • Carry their shopping bags to the car. 
  • Remember names of spouses and kids. 
  • Donate to a cause close to their heart. 
  • Offer discounts or free delivery. 
  • Send a bottle of their favourite tipple. 


4. Draw on past experiences 

An effective way to prepare for the holiday season is to draw on past trends. Review data and customer feedback from past seasons. 

Look at enquiries, sales, returns, complaints, reviews. Spot when you first saw an uplift and when things started to return to normal. Demand data such as this can help you prepare and plan for what might come. 

The more data you have, the better prepared and more strategic you will be. Don’t just consider quantitative data. To improve the customer experience and create WOW moments you need qualitative data. 

Mystery shopping is a wonderful way to see the business through the eyes of the customer. Repeatedly asking for feedback will enable you to understand what you are doing well and show what can be improved. 

Remember, if you’ve invested in data and customer feedback, be sure to use it. Many businesses collect valuable information but many more fail to act on it. 

5. Optimise self-service for higher satisfaction 

Self-service is about enabling customers to answer their own questions whenever possible.  

One of the easiest ways you can do this is through the content on your website. Make sure your content is correct and easily accessible. Spread some holiday cheer by adding festive imagery. 

Create seasonal FAQs which can be added to your homepage to quickly answer specific Christmas related questions. 

Another fantastic way to help with customer self-service is a conversational virtual agent. Live chat and outsourced telephone answering services can support you to meet increased demand. 

 6. Commit to service excellence 

Engaging your employees is critical to business success. Training and developing your staff on the customer experience process is essential so that they can see things from the customer’s perspective. 

A word of caution, having an ill-thought-out customer experience strategy can be more damaging than not having one at all. Managing and implementing feedback is a crucial part of the process, therefore working with the right customer experience partner is imperative. 

At insight6 we understand that feedback is data, not judgement. We use feedback and the experience of our local customer experience specialists to deliver workshops that inspire and motivate teams. 

Are you ready to transform your business? 

Giving an exceptional customer experience can be challenging during the peak periods like Christmas. 

Unfortunately, customer demands and expectations don’t decrease during this busy time. In fact, they are far more likely to skyrocket! 

With the tips shared in this article, you can take essential steps to make your customer experience shine this holiday season. 

But the customer experience is for life (if done right), not just for Christmas. Repeatedly asking your customers or clients, and staff for feedback is critical to building loyalty and driving profitability. 

And that’s where insight6 comes in. 

Our total feedback tool, instant insight, along with our team of local experts, will transform your customer experience. 

By analysing feedback from your team and customers in real-time, instant insight will provide you with actionable comments. You will also be able to generate positive customer online reviews. 

In addition, instant insight enables you to benchmark your business against others within your sector.  

The more feedback you receive, the more confident you will be in making great decisions for your business. 

So, what are you waiting for? Book your instant insight demo with us today and take the first step to delivering a world-class customer experience.