The Consumer Duty & Aviva Investors

Delivering positive outcomes

The Consumer Duty introduces clearer and more rigorous standards for consumer protection within financial services. It mandates that firms prioritise the needs of their customers.

At Aviva Investors, we support the Consumer Duty and the principles that underpin it – especially the focus on achieving positive outcomes for customers.

While the regulation presents challenges, it also opens up new opportunities. We are committed to working closely with our distribution partners, advisors and investors to continuously deliver good outcomes for our mutual retail customers.

To help businesses and customers navigate these regulations, we have included some more information on the purpose, scope, timing, and practical implications of the Consumer Duty below.

The outcomes we aim to deliver:

Products and services

Aviva Investors ensures our products (funds) and Model Portfolio Services (MPS) are fit for purpose and work as expected by ensuring:

- the design meets the needs, characteristics and objectives of customers in the identified target market

- the intended distribution strategy is appropriate for the target market

- the product or service continues to meet the needs, characteristics and objectives of the target market

Price and value

We cannot act in good faith if we are knowingly manufacturing or distributing poor value products or services. To meet this, Aviva Investors ensures:

- the costs of the product are clear

- the outcome offered is easily understood and measurable

- the outcome ties in with defined customer objectives

- the price is set relative to the costs incurred, and the value offered

Consumer understanding

To equip consumers to make good, informed and timely decisions,  we communicate information at the appropriate time in the customer journey to give customers sufficient opportunity to understand and assess their options. To do this we ensure communications are:

- clear, fair and not misleading

- tailored to complexity of products or services and the communication channel used

- tested, monitored and adapted

- considered in context of the role of Aviva Investors in their distribution

Consumer support

Aviva Investors support our customers in monitoring and managing the products or services they have bought to achieve their financial objectives. To do this we ensure:

- support is aligned to the needs of customers throughout their relationship with us

- support is timely, appropriate and delivered through the channels the customers need

- we provide our distributors with all the information they require to support indirect customers

How we measure that we are delivering these outcomes: 

Products and services

We look at who our customers are, how our products and services are performing, and whether they meet customer needs. We also use insights from consumer testing and feedback from our sales and distribution partners.

Price and value

We regularly check that our products and services offer fair value, continuously review investment performance, listen to customer feedback, and analyse any complaints or common concerns raised during customer interactions.

Consumer understanding

We test our communications to make sure they're clear and easy to understand. We also gather feedback through surveys and monitor complaints and queries to identify where we can improve how we explain things to customers.

Consumer support

We track how well we support our customers by reviewing service delivery, customer contact experiences, and complaint and query trends. This helps us ensure customers get the help they need, when they need it.

Value Assessments

Authorised Fund Managers (AFMs) are required to evaluate the value of each share class in every fund they manage at least once a year. The Financial Conduct Authority (FCA) outlines a minimum set of components that must be considered to determine whether a fund offers value and whether its costs and charges are justified.

View value assessments

Consumer Duty at a glance: five questions

What is the Consumer Duty?

Finalised by the Financial Conduct Authority (FCA) on 27 July 2022, the Consumer Duty builds on existing regulations but goes further. It requires firms prove they are working in the best interests of retail customers.

Why was the Consumer Duty introduced?

Individuals are now taking on more responsibility for their financial decisions. But trust in the industry remains low. The Consumer Duty aims to raise expectations as to how firms serve retail customers.

Who does it affect?

The Consumer Duty applies broadly to any firm that has a material influence over retail customer outcomes. This includes firms involved in retail product design, build or operation; those involved in their communication; and those involved in their servicing – across the entire value chain.

When are the key milestones for the Consumer Duty?

The FCA set four key deadlines:

  • 31 October 2022: Implementation plans towards full compliance must have agreed;
  • 30 April 2023: Product reviews against the rules must have been completed by manufacturers;
  • 31 July 2023: Rules apply to open products/services;
  • 31 July 2024: Rules apply to closed products/services.

How can firms demonstrate compliance?

There’s no universal approach. Each firm must provide evidence on how it delivers good outcomes through:

  • Product & services: to show that the design of these continues to meet the needs and goals of the target market.
  • Pricing & value: to show that all products and services give fair value.
  • Customer understanding: to show that all communications are comprehensible and understood.
  • Customer support: to show that customers can realise the benefits of their product or service.

Useful links to FCA Consumer Duty content

The FCA is committed to supporting the success of the Consumer Duty. Below are links to a range of helpful FCA information.