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Consumer Duty Fair Value, Explained: What The FCA Found Three Years In And How To Evidence It

Consumer Duty fair value means a firm can show that what customers pay is reasonable for the benefits they get, using evidence rather than assumptions. On 29 October 2026, three years into the Duty, the FCA said the firms that fell short most often lacked evidence, or had it scattered across documents that were never brought together. This plain-English explainer sets out what the FCA found, the questions it suggests firms ask, and how to pull the evidence into one place that a board can review.

Published  ·  Updated  ·  7 min read  ·  By BraivIQ Editorial

A vintage weighing scale on a desk, for an explainer on Consumer Duty fair value evidence

Key takeaways

  • The FCA published its findings on fair value three years into the Consumer Duty on 29 October 2026.
  • Stronger assessments showed a clear, evidenced link between what customers paid and the benefits they could expect.
  • Weaker assessments relied on assumptions rather than customer data, or had evidence scattered across documents.
  • The FCA asks firms whether they assess fair value for different customer groups.
  • Bringing the evidence together is routine work that software can prepare, with a person reviewing and signing off.

Consumer Duty fair value is the part of the Duty that asks whether the price a customer pays is reasonable for what they get. It sounds simple. The FCA's message on 29 October 2026 was that many firms reach a sensible answer but cannot show how they got there.

What did the FCA find about Consumer Duty fair value?

In a blog published on 29 October 2026, Alison Walters of the FCA wrote that three years into the Consumer Duty there are clear differences between firms that have embedded fair value and those that still need to strengthen their assessments, evidence and monitoring. The FCA looked at how firms across the consumer finance market assess, evidence and monitor fair value, including fees and charges on credit products.

Where firms fell short, the FCA said a recurring issue was the evidence supporting their conclusions. Stronger assessments showed a clear, evidenced relationship between what customers paid and the benefits they could reasonably expect. One credit card provider, for example, quantified cashback and foreign exchange savings.

What does weak fair value evidence look like?

  • **Assumptions instead of data.** The FCA said weaker assessments tended to rely on assumptions rather than actual customer data.
  • **Evidence in pieces.** Some firms had relevant evidence, but it was scattered across documents and never brought together, which made it hard for anyone, including the FCA, to see how they reached their conclusion.
  • **One view of all customers.** The FCA asks firms: “Are you assessing fair value for different customer groups?”

How do you bring fair value evidence together?

Most of the evidence already exists: product charges, usage data, complaints, cancellation rates and benefit take-up. The work is gathering it every period, putting it in one pack, comparing it with last time and highlighting what moved. That is preparation, and it suits automation.

Our MI and board packs workflow does exactly this kind of preparation: it pulls the figures from your systems, checks them against last month and drafts notes for the person who owns the pack. That person approves every number and every word before the pack is circulated. The judgement about fair value stays with your people.

Where does AI help, and where should it stop?

  • **Good uses.** Collecting figures from several systems, spotting gaps, comparing customer groups and drafting a summary of what changed.
  • **Where it stops.** Deciding whether a product offers fair value. That is a judgement for the firm, with the evidence in front of the people who make it.

Our article on regulatory reporting automation covers the same principle for reports: automate the checks, keep the sign-off with a person.

Where should a firm start?

Pick one product, list every piece of evidence you use for its fair value assessment and where each one lives. If they sit in five places, start there. A 14-day Proof Run can put the evidence pack on one product. This article explains a published FCA blog and is not regulatory advice.

Frequently asked questions

What is Consumer Duty fair value?

It is the requirement that the price customers pay is reasonable relative to the benefits they can expect. Firms need to assess, evidence and monitor it for their products.

What did the FCA find about fair value in October 2026?

On 29 October 2026 the FCA said firms that fell short most often lacked evidence for their conclusions, relied on assumptions rather than customer data, or had evidence scattered across documents.

Can AI decide whether a product offers fair value?

In our approach it does not. Software can gather and compare the evidence, but the judgement and sign-off stay with the people responsible for the product.

References

  1. Financial Conduct Authority, "What does fair value look like in practice? Three years into the Consumer Duty, here's what we've learned", 29 October 2026. https://www.fca.org.uk/news/blogs/fair-value-look-practice-three-years-consumer-duty