Category: Compliance & AML · Reviewed by Chrissie Anderson, Client Executive · Last reviewed June 2026
The FCA’s expectation that a non-executive director (or, in firms without NEDs, another independent governance figure) is designated as Consumer Duty Champion to support and challenge the board on its delivery of the Duty.
The Consumer Duty Champion is the FCA’s expectation that each Consumer Duty-in-scope firm with a board appoint a NED-level “Champion” who supports and challenges the board on Consumer Duty delivery. The Champion is not an SMF in itself; it is an additional role function held by a NED that brings dedicated focus to Consumer Duty in board deliberations.
FCA Finalised Guidance FG22/5 paragraph 11.13 explicitly sets the Champion expectation. The Consumer Duty itself sits in PRIN 2A; the Champion is a governance expectation rather than a Handbook rule, but a robust governance arrangement is required to evidence delivery of the Duty.
The Champion’s role typically includes ensuring Consumer Duty is on the board agenda, challenging the firm’s outcome data and remediation plans, supporting customer-centric thinking, and being a point of escalation for vulnerability and outcome issues. In firms without NEDs (many small Core SMCR firms — including most insurance intermediaries), the FCA expects an equivalent independent challenge function — often through a senior compliance figure or an external adviser.
Larger Enhanced firms typically have a NED-Chair-of-Customer-Outcomes-Committee or equivalent. Small Core firms typically allocate the Champion role to a director, with documented arrangements for independent challenge (e.g. a compliance consultant or external NED on a rolling basis). The FCA’s emphasis is on substantive challenge, not formal title.
In a small broker with no NEDs, the Consumer Duty Champion may be the SMF16 Compliance Oversight holder, with independent challenge arranged through engagement with an external compliance consultant and through the firm’s complaints / vulnerability MI being reviewed at each board meeting. The annual board report records the Champion’s challenge and the actions taken in response.
FCA Finalised Guidance FG22/5, paragraph 11.13. FCA Handbook, PRIN 2A. FCA Policy Statement PS22/9.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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