Five crucial improvement areas for Consumer Duty compliance in Banking and Insurance

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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. The regulator wants clear evidence that monitoring is reliable, that vulnerable customers are supported and that dissatisfaction is spotted early.

Since Consumer Duty took effect in July 2023, firms have moved from planning to proving and this is where AI can prove extremely effective, and ultimately essential. The focus is on whether organisations can show consistent outcomes across every interaction. Yet many still depend on systems that only review a small fraction of calls or look for specific words. These methods cannot identify the tone, intent or emotional cues that shape real customer experiences.

To address this, firms need stronger insight, clearer visibility and reliable monitoring across their full customer journey. The five areas below are where improvements matter most and AI is going to be crucial in supporting these.

  1. Quality Assurance: From sampling to full coverage

Consumer Duty expects firms to demonstrate consistent outcomes across every interaction. This is difficult when traditional QA only reviews a small sample. Manual sampling worked when interaction volumes were low and processes were simpler. Today it leaves firms exposed.

These methods cannot identify the tone, intent or emotional cues that shape real customer experiences.

AI reviews every conversation and highlights issues that require expert attention. This allows QA teams to focus on coaching, support and continuous improvement. Firms using AI-enabled QA reach full coverage while reducing assessment time by more than 70 percent. This improves compliance and strengthens customer service.

  1. Agent Conduct: real-time insight and better coaching

Consumer Duty requires clear explanations, appropriate tone and accurate handling of mandatory information. This is particularly important in forbearance, claims, complaints and affordability conversations.

AI-driven monitoring identifies gaps in real time. It highlights knowledge issues, tracks improvement and shares examples from top performers. This shifts coaching from periodic reviews to continuous development and links training directly to outcomes.
3. Executive oversight: visibility into causes, not only numbers

Boards often receive summary KPIs that show complaint volumes, call quality scores or interaction totals. Consumer Duty expects a deeper level of understanding. Leaders must know why issues occur, how often they appear and whether actions taken are effective.

AI-enabled analysis surfaces themes, patterns and verified examples so leaders can make decisions based on real customer experiences, not assumptions.

  1. Complaints Management: capturing dissatisfaction early

The FCA expects firms to identify every expression of dissatisfaction, not only formal complaints. Many customers do not complain through official channels. They show concern, frustration or confusion during everyday conversations.

Keyword systems rarely detect these early signals. AI reviews full context, including tone, hesitation and sentiment. This allows firms to address dissatisfaction early and provide evidence of proactive management to the FCA.

  1. Vulnerable Customers: continuous identification throughout the journey

Consumer Duty requires firms to identify vulnerability in every interaction. Vulnerability is dynamic. It changes with life events, financial pressure, health issues and emotional strain. Customers seldom declare it explicitly.

AI models trained on sector-specific data identify patterns that suggest vulnerability. They ensure every conversation is reviewed so teams can intervene quickly and provide sensitive, appropriate support. Human judgement remains essential. AI ensures that no signal is overlooked.

The future landscape

Manual processes and keyword systems cannot meet Consumer Duty expectations at scale. Banks and insurers that succeed have adopted AI-powered conversation intelligence to reach full oversight, improve service quality and reduce pressure on compliance teams.

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About Author

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Jamie Hunter is Chief Operating Officer at Aveni.ai. He spent 13 years in the investment industry and latterly was Head of Business Partnering and Planning for Aberdeen Standard Investments.

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