Consumer Duty fair value assessment: evidence of what customers are actually shown

A Consumer Duty fair value assessment is a UK financial firm’s documented test, under PRIN 2A.4 of the FCA Handbook, that a product’s expected total price is reasonable for the benefits each group of its customers can expect. The FCA’s October 2026 findings say the weakest assessments rest on assumptions, outdated fee lists and headline price comparisons. Obsession keeps what your firm and its competitors show customers after sign-up, from fee wording to signed-in rates and renewal notices, each dated with its screenshot, by API or MCP, the standard way AI agents call tools.

A Consumer Duty fair value assessment is the written test that a financial product’s total price is reasonable for the benefits its customers can expect. It has to hold for every group of customers the product serves, and for as long as they are likely to keep it. Conduct, product governance and customer journey teams at UK banks, lenders, insurers and fintechs own it. The Financial Conduct Authority (FCA) says its weakest part is evidence of what customers are shown and charged.

Each rule here is summarised from the FCA Handbook and the FCA’s own guidance pages as they stood on 11 November 2026. General information, not legal or regulatory advice.

The price and value outcome: what PRIN 2A.4 requires

The Consumer Duty is Principle 12 of the FCA’s Principles for Businesses, with its detailed rules in chapter PRIN 2A of the Handbook. Those rules came into force on 31 July 2023 for products on sale or open to renewal, and on 31 July 2024 for closed products, which are no longer sold or renewed.

The price and value outcome is PRIN 2A.4. Its first rule, PRIN 2A.4.1R, defines value as the relationship between what a retail customer pays for a product and the benefits they can reasonably expect from it. A product gives fair value where the amount paid is reasonable relative to those benefits.

The duty falls first on the manufacturer, the firm that makes the product. Under PRIN 2A.4.2R it must make sure each product gives fair value to customers in its target market. It must also carry out a value assessment and review it regularly, at intervals that suit the product’s nature and duration. PRIN 2A.4.3R requires the first assessment before a product, or a significant change to it, is marketed. Under PRIN 2A.4.5R the firm must be satisfied that the product will stay fair value for a reasonably foreseeable period, including after any renewal.

PRIN 2A.4.8R sets what every assessment must consider, as a minimum:

• the nature of the product, including the benefits customers can reasonably expect and its quality
• any limitations that are part of the product
• the expected total price: the price agreed at the start, regular charges over the product’s life, contingent charges such as arrears fees, and any non-financial costs the customer is asked to provide
• any characteristics of vulnerability in the target market, and how far they make it less likely a customer gets fair value

Guidance at PRIN 2A.4.9G adds factors a firm may weigh. They include its own costs, the market rate and charges for a comparable product, and accrued costs and benefits on existing or closed products. They also include whether products priced significantly lower give a similar or better benefit. PRIN 2A.4.10G names personal data, and permission to use it, as a non-financial cost. PRIN 2A.4.11G asks firms to check fair value for each group of customers in the target market, including where different groups pay different prices. PRIN 2A.4.20R stops a firm leaving the judgement to individual customers in place of its own assessment.

Distributors carry their own duty under PRIN 2A.4.16R: their arrangements, including any remuneration, must be consistent with the product giving fair value. Where a review finds a product no longer gives fair value, PRIN 2A.4.25R requires the manufacturer to mitigate harm to existing customers, remediate it where appropriate, and prevent harm to new ones.

Under PRIN 2A.4.32R, the section doesn’t apply to non-investment insurance products, certain funeral plans, or authorised fund managers for products under the fund rules in COLL. Those firms keep applying their own product governance rules, PROD 4 for insurance, and the evidence questions that follow are useful for an insurer’s fair value file too.

Where fair value meets the rest of the Duty

A fair value conclusion leans on the other outcomes. In the consumer understanding outcome, PRIN 2A.5.3R requires a firm’s communications to meet customers’ information needs and be likely to be understood. They must also equip customers to make effective, timely and properly informed decisions. PRIN 2A.5.5R says timely means before purchase and at suitable points through the product’s life. PRIN 2A.5.10R asks firms, where appropriate, to test communications before sending them and monitor their effect afterwards.

PRIN 2A.9.8R requires firms to monitor the outcomes customers get from their products, their communications and their customer support. Under PRIN 2A.9.9R that monitoring must show whether products give fair value, and under PRIN 2A.9.10R whether any group of customers gets worse outcomes than another group using the same product.

The results reach the top of the firm. PRIN 2A.8.3R requires a report to the governing body on that monitoring and the actions it calls for. Under PRIN 2A.8.4R the governing body must, at least once a year, review and approve the report and confirm whether it is satisfied the firm is meeting the Duty.

Consumer Duty fair value assessment template

The FCA doesn’t prescribe a template. Its October 2026 findings on fair value in consumer finance say its examples create no new requirements. A few smaller firms, it notes, built their assessments around the 5 areas of its May 2023 review of fair value frameworks: understanding of the requirements, costs and benefits, contextual factors, differential outcomes, and data and governance. Each part of this template maps to the rule behind it and the evidence that supports it.

Most rows can be filled from the firm’s own files. Two can’t: market comparison and value over time. Both need evidence of what a customer is shown outside the firm’s systems, at the firm itself and at its competitors.

Where the evidence is weakest

The FCA’s October 2026 findings come from reviews of consumer credit, debt advice, credit reference and debt collection firms. Weaker assessments:

• relied on narrative statements, assumptions or hypothetical models instead of customer data
• rested on incomplete or outdated information; one counted a fee no longer charged and left out a fee customers could still incur
• benchmarked headline prices without allowing for features, service or target market, or didn’t explain why the comparators were chosen
• monitored outcomes for the whole portfolio, without checking whether they differed between customer groups
• gave little thought to how value changes over time, through renewal, fee changes or arrears

On communications, the FCA saw material fees disclosed late in the application journey. Fee information was spread across several pages and documents, and the amount, timing or frequency of some charges wasn’t clear. Its May 2023 review made a related point about comparisons. A comparison with other firms can hide fair value problems common across a whole market, and averages can hide pockets of poor value.

Read together, the findings point at one gap. A fair value file is mostly built from inside the firm. It draws on the fee schedule, the terms, the product approval papers and management information (MI), the firm’s own data on complaints, cancellations, arrears and usage. Those show what the firm intended to charge and say. They don’t show which screen of the application first showed a fee, or what the renewal email said on the day it arrived. Nor do they show what chat answered when a customer asked whether a rate was fixed, or what competitors offer a customer once the form is filled in.

How to evidence what customers are shown

The method works for a firm’s own products and for the competitors it benchmarks against. Each step ends with what a pass looks like.

1. List the moments that set the price. The application, the first email or statement, any rate or fee change, the end of an introductory rate or fixed term, renewal, arrears, and cancelling or switching. Each is a point where PRIN 2A.5.5R expects information in good time.
2. Walk the journey as a new customer. Go through it outside the firm’s systems, on the website, in the app and in chat, and save every screen with the date and time. It passes when every charge in the assessment appears before the customer commits, in the same words as the terms.
3. Reconcile the fee list. Check the expected total price in the assessment against what the journey and the live terms show. It passes when no live charge is missing and no retired one is still counted, the mismatch the FCA found in one assessment.
4. Ask the questions customers ask. Put the price questions to chat, email support and the phone line: is this rate fixed, what happens when the bonus ends, what does it cost to leave early. It passes when every answer matches the terms. Real cases of chatbots giving customers the wrong answer are collected in AI chatbot fails.
5. Follow the product past day 1. Keep every renewal notice, rate change email and end of term letter, and count the steps and minutes it takes to cancel or switch. The FCA’s findings treat that time and effort as a non-financial cost. A useful pass mark: each notice arrives before the change with the new price stated, and leaving takes no more steps than joining.
6. Benchmark past the headline. Choose comparators and write down why each is comparable in features, benefits, target market and service, as the FCA’s findings ask. For each, record the public rate, the rate an existing customer is paid, any offer shown only after the form, and the quote for the same customer profile, each dated. It passes when a reviewer can see why each comparator was picked and what its customers are shown.
7. Split by customer group. Compare what new and existing customers, each channel and each profile are shown and charged. It passes when every difference has a reason backed by evidence, as PRIN 2A.4.11G and PRIN 2A.9.10R expect.
8. Date it and run it again after every change. A price change, a new journey, a chatbot update or a competitor’s new offer each starts the clock again. It passes when the governing body report can point to a dated record behind each conclusion.

The same gap between the public price and the signed-in one drives member-only pricing in retail and travel, and the full competitor template for banks is in bank competitor analysis.

In the Fernbank example, the dated findings turn into actions the governing body can follow.

What a gap in the evidence can cost

When a review finds a product no longer gives fair value, PRIN 2A.4.25R asks for mitigation and, where appropriate, remediation. The size of that bill grows with the customer base, which is why evidence that catches a gap in its first week is worth more than evidence found at the annual review.

Put in the product’s own numbers: the customer count from the product file, the share charged from fee MI, and the charge from the live terms.

Ways to gather the evidence, compared

We make Obsession, so every other option is described as firms use it today, as of 11 November 2026.

Use Obsession when a conduct, product governance or journey team needs dated evidence of what customers are shown, at its own firm and across its competitors, repeated after every change. Your own MI stays the core of the outcomes evidence, and comprehension testing tells you whether customers understood. For one product with a single published charge, a yearly walk-through by hand is enough.

Dated evidence from the customer’s side

Obsession collects what companies show only to customers, step by step: their screens, emails and texts, member prices, trial limits, quotes and cancel offers, each dated with a screenshot. Teams and AI agents look up any company through the API or MCP, and a company not yet covered is added on request.

Search engines and comparison sites stop at the public rate page. Obsession collects what a firm shows past the login and the form, the web behind the login. For banks and fintechs, Obsession keeps each step of account opening, every email and text after it, signed-in rates beside public ones and offers shown after the form. It keeps what chat tells a customer too, at your own firm and every competitor you name, for as long as you follow them. The same record shows what a customer meets when they leave: each cancel step, and every email or text after an unsubscribe (opt-out and cancel checks for compliance teams). Obsession’s agents have run 1,500 sign-ups, baskets and checkouts at real companies, and counting. The sample data shows everything collected from one real store.

Questions about Consumer Duty fair value assessments