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The Consumer Duty document library

Last updated: 01 July 2026

In line with regulatory requirements, Consumer Duty Target Market Statements and Value for Money Assessment Outcomes will be hosted on this page annually.

Purpose of Disclosure - This page is designed to host our Consumer Duty Target Market Statements and Value for Money Assessment Outcomes. It is for adviser use only. Not to be used with customers.

Consumer Duty is one of the biggest events shaping our industry presently, and more so in the years to come.

At Sapphire, we support the Consumer Duty and its principle of acting to deliver good outcomes for customers. While it will bring change and challenge but we also see it as an opportunity for growth and improvement. We are committed to collaborating with the wider community to ensure the successful implementation and execution of the Consumer Duty, working together to enhance the overall well-being and satisfaction of our customers.

Discover more about Consumer Duty by visiting the Sapphire blog - FCA PS22/9: What Consumer Duty means to Sapphire. Otherwise, here are the five key basics to Consumer Duty:

1

Why has Consumer Duty been introduced?

Individual responsibility for personal finances is greater than ever, but public trust in the personal finance industry remains weak. By raising regulatory expectations, Consumer Duty seeks to promote trust, responsibility and transparency within the industry and empower consumers to make informed financial decisions.

2

What is Consumer Duty?

The FCA published its final Consumer Duty Rules on 27 July 2022. Consumer Duty builds on previous regulations, but goes further. Consumer Duty demands that all who operate in this market must evidence that they are “acting to deliver good outcomes for retail customers”.

3

Who is impacted by Consumer Duty?

The scope of the Consumer Duty is wide. It applies to all firms who have a material influence over retail customer outcomes. For example, it applies to firms involved in the design, build or operation of retail products or services; firms involved in their distribution; firms involved in their communication; and firms involved in their servicing.

4

When is Consumer Duty being implemented?

The FCA has set four Consumer Duty deadlines:

  • 31 October 2022: Implementation plans towards full compliance must have been agreed
  • 30 April 2023: Manufacturers must have completed product reviews against the rules
  • 31 July 2023: The rules apply to all open products and services
  • 31 July 2024: The rules apply to all closed products and services
5

How can a firm demonstrate compliance with Consumer Duty?

This is the big question. There is no “one-size-fits-all” answer. Each firm must consider how it can evidence it is acting to deliver good outcomes. And four outcomes must be scrutinised:

  • Products & services: to evidence that the design of all products and services continue to meet the needs, characteristics and objectives of their target market
  • Price & value: to evidence that that all products and services give fair value
  • Consumer understanding: to evidence that all communications are understandable and understood.
  • Consumer support: to evidence that all customers can realise the benefits of their product or service.

Sapphire entities achieve fair value from their products, and good customer outcomes, by having embedded sound principles of product oversight and governance through the operation of its Risk and Compliance Committee, which collectively is responsible for both the design, delivery, and monitoring of our products where we are a manufacturer or a co-manufacturer.

Our target markets are defined at an appropriate level, based on the nature and complexity of our products.

We monitor performance of our products throughout their lifecycle, to ensure they meet our customers’ needs and provide fair value.

Our products are subject to annual assessment and review in conjunction with insurers to ensure products provide fair value for customers.

We review our distribution channels and the remuneration they receive to ensure they are appropriately targeted.


Sapphire's Consumer Duty product packs offer comprehensive information to ensure your client's case file complies with the latest regulations.

Each pack includes:

- Details on how Sapphire prioritizes positive outcomes for customers;

- An evaluation of the investment against the four outcomes of Consumer Duty;

- Essential technical information, including fees.


Whether you have previously done business with Sapphire or are currently working on a case, these documents will be invaluable to you.

Consumer Duty Product Pack

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