What does 'fair value' look like in practice? Three years into the Consumer Duty, here’s what we’ve learned.

While some firms have successfully embedded fair value into product design and pricing, others struggle to substantiate their conclusions, particularly in consumer finance, fees and charges, and niche areas like consumer hire and energy infrastructure agreements. For compliance teams, this signals heightened supervisory scrutiny and potential enforcement risk. Firms should urgently review their fair value frameworks, ensuring robust evidence and ongoing monitoring.

Key actions include reassessing product value propositions, documenting decision-making, and enhancing oversight of fees and charges. The FCA expects firms to demonstrate that prices are reasonable relative to benefits, not just assert it. This is a reminder that fair value is not a one-off exercise but requires continuous evaluation.

Firms that proactively strengthen their approach can mitigate risk and build competitive advantage through better customer outcomes. However, those lagging may face regulatory intervention. Overall, the message is clear: evidence matters.