The Duty Champion

Governance & Accountability

Operating Model

All Sectors

The FCA originally required firms to appoint a Consumer Duty Champion at board level. In February 2025 it gave firms flexibility to retain the role or fold it elsewhere. Many retained it, citing senior accountability. The question that flexibility exposes is one most firms quietly avoided in Year 1: how many of those roles actually function? The FCA's review of first-year board reports found Champions often included as a name in the governance section but the report itself produced almost solely by Compliance, with the board's challenge rarely documented in minutes. The structural problem is that a Champion role can be appointed without designing the conditions under which it can challenge effectively.
In February 2025 the FCA confirmed firms are not required to retain the named Champion role; they may retain, dissolve, or replace it. That is nomenclature. The structural challenge — designing senior board-level Duty challenge with independent data, real influence at the point of decision, and the authority to use it — is unchanged whether the role keeps its title, takes a new one, or sits within an existing committee remit:
Independent data and analysis access
The Champion (or equivalent challenge function) has a defined right to commission analysis, request raw data, and receive MI directly — not filtered through the executive paper-production process. This includes complaint root-cause analysis, vulnerability indicator trends, fair value cohort breakdowns, distribution chain outcome data, and customer outcome dashboards drawn from source systems. The right is named in the role's terms of reference, supported by an analytical resource the role can task without executive sign-off, and exercised as a standing practice rather than reserved for crisis. The design test: in the last year, has the role surfaced a customer outcome issue from data the executive did not present in a board paper?
Formal challenge rights at the point of decision
The role has a documented standing in the governance forums where customer-affecting decisions are actually made — product approval, pricing committees, distribution partner reviews, remuneration committee, target market change governance, complaint handling and root-cause forums. This may mean the Champion attends, a delegate attends, or a defined escalation route runs from those forums to the role. Decisions in scope cannot be finalised without a recorded position from the Champion, and a dissent — formally noted — triggers a defined escalation path to the chair. The design test: identify three decisions in the last year where the Champion's recorded position changed the outcome, delayed the decision, or was overridden with documented justification.
Structural independence and documented authority
The role's authority is structural, not personal. The remit is documented in writing, the time commitment is sized realistically (not added to a portfolio of unrelated committee chairs as an afterthought), the reporting line is explicit (typically to the chair or the senior independent director, not to the CEO), and the appointment is for a defined term with succession planning. Where the Champion is an NED, their independence under FRC governance code provisions reinforces the role; where the Champion is an executive, additional structural safeguards (named challenge rights, documented dissent mechanism, direct chair access) compensate for the conflict. Crucially, the challenge log is documented — questions asked, evidence requested, action items closed — so the role's contribution is visible to successor Champions, the wider board, internal audit, and the FCA when asked. The design test: if the current Champion left tomorrow, would a successor inherit a working role with documented standing, or would the function reset to ceremonial until they personally rebuilt it?
- The Champion (or equivalent challenge function) maintains a documented challenge log — questions asked, evidence requested, decisions affected, items closed — that is visible to internal audit and forms an annex to the annual Duty board report.
- Board and committee minutes show evidence of substantive Duty challenge with named questions, requested follow-ups, and closure status — not generic statements that the report was reviewed and approved.
- The role has independent access to customer outcome data, complaint root-cause analysis, and distribution chain outcome MI — exercised at least quarterly, not just for the annual review — and the analytical resource supporting the role can be tasked without executive sign-off.
- Decisions on product approval, pricing, distribution partner appointment, target market change, and remuneration scheme design carry a documented Champion (or equivalent) position before they are finalised, with at least one substantive challenge or dissent recorded in the past year.
- A retail bank reviewed its Duty Champion arrangements after the February 2025 FCA flexibility announcement and concluded the role had drifted toward ceremonial during Year 1. The board commissioned a redesign before deciding whether to retain the title. The redesigned role added three structural elements: a direct reporting line from the customer outcomes data team to the Champion's office (independent of the executive's paper-production cycle), standing observation rights at the product approval committee and the remuneration committee, and a documented dissent mechanism whereby any recorded Champion position against a decision triggered a chair-level review within ten working days. In the first six months, the Champion used the new dissent mechanism twice — once on a savings rate tier proposal that produced a regressive outcome for inert long-tenure customers (the proposal was reworked before launch), once on a branch incentive scheme that placed throughput weight ahead of fair value (the scheme weighting was rebalanced and a malus condition added). The board retained the Champion title rather than dissolve it, but the substantive change was the documented challenge architecture, not the name. The Year 2 board report, when it landed, included a Champion's challenge log as an annex — the kind of evidence the FCA's good practice review had specifically said most firms had been unable to produce.
- A wealth manager took the opposite approach to the February 2025 flexibility — it dissolved the named Duty Champion role and consolidated the challenge function into the audit and risk committee chair's remit, on the rationale that the chair already had the structural independence and the access to internal audit. The transition was deliberate. The terms of reference for the audit and risk committee chair were rewritten to include the Champion responsibilities as a named element, an additional half-day per month of dedicated time was scoped, and the platform's customer outcome dashboard was rebuilt to feed the chair's office directly rather than via the executive committee. The first issue the consolidated function surfaced was an ongoing-advice charge cohort: a segment of clients was paying the full ongoing-advice fee but had not received a suitability review in the previous twenty-four months — the FCA's October 2024 ongoing advice review had highlighted this as a 17% market-wide problem. The chair tabled the cohort at the audit committee, the executive committed to a remediation programme with a defined fee-suspension trigger and outreach plan, and the board minute recorded the challenge in the form the Year 2 blog had said most firms had been unable to produce. The lesson is not that dissolving the named Champion is correct — it is that the function survives a name change only if the design challenge is taken seriously.
Common failure modes
The most common failure mode is the role appointed without the conditions for it to function — a Champion with no independent MI feed, no standing right to commission analysis, no formal challenge channel into product, pricing, distribution, or remuneration decisions. The role's existence then provides the appearance of senior Duty challenge while shielding the executive from the substance of it. A second is the annual-report-only Champion: visible once a year in the board Duty report, functionally invisible in the months when the decisions that matter are made. A third, surfaced explicitly by the Year 2 blog, is the undocumented challenge — the board reviewed the report, the Champion was present, the discussion happened, and there is nothing in the minutes that would tell the FCA, or a successor Champion, what was actually contested. A fourth is appointing the most amenable senior figure rather than the most willing to use the role; the structural test is whether they have, in their previous tenure, gone on the record against management on a substantive issue. A fifth, particularly relevant where firms have dissolved the named role since February 2025, is silent dissolution: the title is removed, the function is described as 'embedded across the board', and no individual now holds the standing remit, data access, or documented challenge rights the role previously concentrated.

Related Patterns

Evidence & Supporting Facts

FCA Year 2 Consumer Duty Board Reports blog (April 2026) confirmed many firms chose to retain the Consumer Duty Board Champion after the February 2025 flexibility, citing senior accountability as central to cultural change and embedding the Duty — but found that while most boards reviewed and approved their reports, many did not adequately document the challenge they provided, making it difficult to see how senior leaders tested the evidence given to them.

FCA review of 180 Year 1 Consumer Duty board reports (December 2024, updated February 2026) flagged that some reports were produced almost solely by Compliance or a dedicated Consumer Duty function — risking the report missing the scrutiny and input of key stakeholders with subject matter expertise — and noted that the Duty Champion's positive influence was visible in some reports but absent in others, with effective challenge from the governing body not always evident in board minutes.

FG22/5 (the FCA's Final Guidance on the Consumer Duty, July 2022) stated firms should have a champion at board (or equivalent governing body) level. The February 2025 FCA position made retention of the named role a firm choice rather than an explicit expectation, but did not change the underlying expectation of senior board-level Duty challenge — placing the design weight on the function rather than the title.

The FCA 'Culture is Contagious' speech (Emily Shepperd, 4 February 2025) framed senior leaders' role as actively maintaining the conditions in which challenge can occur, citing psychological safety as the defining factor in high-performing teams; and the SM&CR review (PS26/6, Phase 1 changes effective 24 April 2026) reinforces the underlying accountability architecture against which any Duty challenge function operates.

AI Automation Lens

Independent data access is the structural ingredient most amenable to AI support. A Champion who has to wait for executive-prepared papers can use natural language processing and dashboarding tools to commission a parallel view of customer outcomes — complaint root-cause analysis run on raw complaints text rather than committee summaries, vulnerability indicator trends from frontline interaction logs rather than aggregated MI, distribution chain outcome signals pulled from partner data flows rather than relationship-manager reports. Machine learning can surface cohorts whose outcomes are diverging from the firm-wide average and present them to the Champion before the board paper does — restoring the time-asymmetry the role needs to challenge. Sentiment analysis of customer-facing communications and call transcripts can give the Champion an independent read on the consumer understanding outcome, separate from the framework the executive uses to evidence it. NLP applied to the Champion's own challenge log and to board minutes can test whether challenge raised in one cycle was actually closed out in the next, surfacing the unresolved-issues backlog the Year 2 blog said many firms could not document. Critically, the AI lens is not a substitute for the Champion's authority, judgement, or willingness to dissent — those are personal and structural, not technical. AI provides the parallel evidence base that makes challenge defensible and consistent, so the role does not depend on the executive volunteering the inconvenient view of the firm.