Consumer Duty. Complaints. Vulnerability. The regulatory evidence is increasingly converging. The next step in Conduct is not another dashboard. It is connecting what firms already know.
Four signals executives should have on their radar
Over the past year, four pieces of FCA work have pointed in the same direction.
Boards must go beyond MI
In April 2026, the FCA said firms should draw conclusions, identify emerging risks and explain what the data says about customer outcomes.
Monitoring should drive action
In July 2026, the FCA said outcomes monitoring is more than collecting data: firms should spot emerging risks and act before harm occurs.
Vulnerability is being embedded
In September 2026, the FCA highlighted stronger practice that embeds identification across journeys and uses complaints, interactions and MI to improve outcomes.
Complaints reporting is changing
From 1 January 2027, the first period for the unified complaints return begins, and it includes two specific vulnerability data points.
One customer. Three regulatory lenses.
Each of those signals looks at the same customer through a different lens. Consumer Duty sets out what outcomes should be delivered. DISP and complaints show where customers signal failure. Vulnerability shows who may experience outcomes differently.
Triangulate the three and you get Conduct Intelligence: connected evidence, earlier insight and better questions.
The gap is increasingly between the datasets.
A product can look acceptable in Consumer Duty MI, complaints can remain within tolerance and vulnerability controls can appear sound, while the connected evidence tells a different story.
What leading practice is starting to look like
The FCA’s stronger-practice examples increasingly show the same pattern: broader evidence, better segmentation, root-cause analysis, customer-journey thinking and clearer links from insight to action.
In practice, that means connected Conduct becomes part of the operating model, following the evidence all the way from product to action:
Where AI changes the equation
What AI can do
AI can help firms connect complaints, vulnerability, products, journeys and outcomes. It can detect changing patterns and emerging cohorts, surface relationships that conventional thresholds may miss, and focus human investigation on where risk may be developing.
What AI should not do
It should not make the Conduct decision. Conduct remains contextual. Vulnerability is sensitive. Correlation does not establish causation. Human judgement, governance and accountability remain fundamental.
Four board questions for 2027
The real opportunity is not to automate Conduct. It is to make connected Conduct intelligence part of the firm’s DNA, so emerging harm is easier to see, explain and act on.
- 16 Apr 2026 · Year 2 Consumer Duty Board Reports: progress and what comes next
- 27 Jul 2026 · Outcomes monitoring: why understanding the consumer experience matters
- 17 Sep 2026 · Payments firms: delivering good outcomes for consumers in vulnerable circumstances
- PS25/19 · Improving the complaints reporting process: first new reporting period starts 1 Jan 2027
- 8 Jun 2026 · AI in financial services: shaping our approach through industry engagement
