Consumer Duty: the 48-hour question every UK FS CTO should be ready for
Could your firm produce defensible, up-to-date Consumer Duty test evidence within 48 hours of a supervisor’s request, without a special effort?
That is the question. If the honest answer is no, you are operating below the regulated-enterprise floor on Dimension 6 of the QA Maturity Framework, and you are exposed in the part of the supervisory cycle that is most likely to escalate. This post is the short version of why that question matters, what it actually tests, and what the firms that pass it have built.
The 2025 enforcement pattern
In 2025 the FCA issued over £124 million in fines and had six active Consumer Duty investigations underway including two in insurance. The pattern across the cases that have been examined is consistent: the failures customers experienced were technical — mis-stated terms in policy documents, claims processing delays at peak load, journeys that excluded users with accessibility needs, value language a customer could not understand. Each of those is a testing failure before it is a compliance failure. The technology produced the customer outcome; the test estate either evidenced that the outcome was correct or it did not.
In 2026 the FCA’s published supervisory strategy names Consumer Duty as a multi-year priority. That means the question above will be asked, and asked routinely. The firms that pass it cleanly do not pass because they have more lawyers; they pass because their test estate produces the evidence as a by-product of normal delivery. The firms that fail do so because the evidence has to be assembled by hand under time pressure, every time it is asked for.
What ‘defensible Consumer Duty test evidence’ actually means
The supervisor is not asking for your unit test coverage percentages. The supervisor is asking whether your testing demonstrates that your technology delivers the four Consumer Duty outcomes — products and services, price and value, consumer understanding, consumer support — for the target population, including vulnerable customers. The evidence has four parts and each part is testable:
• A test-to-obligation mapping. A current document showing which tests evidence which Consumer Duty outcome.
• Recent test execution evidence. Pass/fail results, dated, signed off, traceable to the release that produced them.
• Defects raised, triaged, and closed in scope of Consumer Duty obligations, with closure rationale.
• A customer-impact log. Where a defect escaped to production and affected customers, what was done, when, and at what scale.
If your firm cannot produce any of these four within 48 hours, that is the gap. The fix is not faster lawyers; the fix is putting the evidence into the same place as the test results, automatically, every time a test runs. That is what ‘as a by-product of delivery’ means.
The four outcome areas, expressed as test types
Consumer Duty does not introduce new categories of testing — every UK FS firm already runs functional, accessibility, content-correctness, and pricing tests. What Consumer Duty changes is who reads the test results, and how quickly the results can be produced on demand. The four outcome areas map to test types as follows:
• Products & Services → functional correctness across personas; vulnerable customer journey tests; accessibility (WCAG 2.2 AA) across affected surfaces; cross-channel consistency; target market segmentation test data coverage.
• Price & Value → pricing calculation correctness; fee and charge disclosure accuracy; value-language consistency between marketing, contract and statement; promotional offer expiry and step-up pricing correctness.
• Consumer Understanding → customer communication content review (automated and manual); readability and reading-age tests on key communications; multi-channel communication consistency; accessibility of communications (screen-reader, alt text, captions).
• Consumer Support → end-to-end support journey functional tests; performance and resilience tests; wait-time and resolution-time monitoring against thresholds; vulnerable customer flow validation; complaints journey functional and accessibility tests.
How to read your own posture
There is a self-assessment scorecard in the full Consumer Duty Test Coverage Playbook — ten statements scored zero to two each, total out of twenty. The bands are honest. Below seven means the firm is exposed and the supervisory risk is material. Seven to twelve means foundations exist but inconsistently. Thirteen to sixteen means the evidence is producible. Seventeen to twenty means evidence is a by-product of delivery and the firm is audit-ready. The bands are easy to dispute in the abstract; they are difficult to dispute when scored honestly against what your test estate can actually produce in 48 hours.
The structural change most firms need
If you have read this far and the question at the top of the page is uncomfortable, the structural change is not enormous. It is mostly about turning four existing things into one continuous process. The four are: your test-to-obligation mapping (today usually a one-off document), your test execution evidence (today usually in a test management tool), your defect triage with a Consumer Duty lens (today usually a separate compliance ticket), and your customer-impact log (today usually only built after an incident). Wire those four together so that every release produces all four artefacts automatically, and the 48-hour question becomes routine.
Get the operating instrument
The Consumer Duty Test Coverage Playbook sets out exactly how to do this — the test coverage matrix, the evidence architecture, the automation feasibility by test type, and the self-assessment scorecard. £495. View the Consumer Duty Playbook →
Prefer the wider picture first? Consumer Duty is one of eight dimensions in the QA Maturity Framework, free at regaltech-global.com. Either way, the question at the top of this post should be one your CTO can answer on any given Tuesday morning — not the one that triggers a fire drill.
— Nipun Kumar, Founder & CEO, Regal Tech Global Delivery Systems
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