
Breaking down language barriers: Improving support for customers in debt
New CSA research highlights how firms can identify language needs early and provide effective, proportionate support for customers experiencing financial difficulty.
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New CSA research highlights how firms can identify language needs early and provide effective, proportionate support for customers experiencing financial difficulty.

At the end of 2025, Elephants Don’t Forget were joined by Jonathan Pearson, Head of Department for Consumer Policy and Outcomes at the FCA, for our end-of-year stakeholder event to discuss what the next chapter of Consumer Duty would mean in practice for firms in 2026.

Beyond performance: A view on why financial services firms must reframe training, competence, and workforce assurance in a Consumer Duty era Introduction The regulatory landscape for financial services firms is undergoing a profound shift.

According to the much-respected biannual UK Customer Satisfaction Index (UKCSI) into national standards of customer service in the UK, we have turned a corner and the seemingly continual slide into customer service oblivion has been reversed. It is certainly worthy of note, but perhaps not yet celebration.

The FCA’s Consumer Duty requires firms to take “reasonable steps” to deliver good outcomes for customers. Most firms believe they meet that standard. The challenge is that the FCA’s interpretation of what is “reasonable” has evolved significantly since the Duty came into force in July 2023.

Vulnerability is derived from the Latin word vulnus meaning wound, injury, or emotional hurt. Is it time to find a different word or drop it altogether? Whether you have clients or customers, I have, for consistency, used the word customer throughout this article. Coming up for three years ago, the FCA implemented the Consumer Duty.

In 2026, the role of Training & Competence (T&C) managers in UK financial services isn’t just about continued administrative compliance. As firms build out AI, data, cloud and outsourced capabilities – and as our supervisory environment evolves – competence management is becoming a strategic function critical to compliance, resilience, culture and business success.

Did you know that we forget a huge amount of what we learn, and even when we do something on a regular basis, we manage to develop bad habits, forget key things, and even change facts to fiction? The brain is an amazing thing, but what it isn’t is foolproof or perfect.

Financial misinformation is no longer a fringe annoyance; it is a mainstream risk that increasingly shapes the choices of people already under pressure from debt, the cost of living, and economic uncertainty.

Financial pressure, complex claims and rising customer expectations are reshaping how banks and insurers operate. Every day, customers call with worries about bills, uncertainty about policies or difficult life events. These moments matter, and the FCA is paying close attention to how firms handle them.

I’m writing this article a week before the deadline for the second annual Consumer Duty Board Report (CDBR#2). Working with friends at Ocorian, our in-house regulatory expert, Chris Adlard, and several other knowledgeable people, the subject of the second Board Report inevitably came up.

In the world of financial advice, trust is everything. It brings clients through the door, keeps them coming back, and prompts them to recommend you to others.