Blogs
26th August 2025
The UK insurance sector is facing a significant shift in how it approaches consumer protection and fairness. The introduction of the FCA’s Consumer Duty has set a new regulatory standard for insurers, Managing General Agents (MGAs), brokers, and other distributors. Central to this is the concept of fair value a principle designed to ensure that financial products meet the needs of the customers they’re sold to, and that consumers are protected from poor value or unnecessary costs. For many firms, however, implementing fair value standards is far from straightforward.
One of the primary obstacles in achieving compliance with the Consumer Duty is the data challenge. Ensuring that products offer fair value requires accurate, timely, and complete data across the entire distribution chain. But this is easier said than done. Data often resides in disparate formats such as PDFs, spreadsheets, Word documents, and legacy systems, making it almost impossible to collect, analyse, and report on in a meaningful way. The lack of clarity, consistency, and integration leads to inefficiencies, increases the risk of errors, and results in missed opportunities to spot potential compliance issues before they escalate.
Many firms are still relying on outdated tools such as spreadsheets, email chains, and manual processes to track and manage this critical information. These legacy systems are not only time consuming but also prone to human error. As a result, firms struggle to maintain oversight of their products, which could put their fair value compliance at risk. This ongoing challenge requires a fresh approach, one that combines technology and streamlined processes to meet the FCA’s expectations.
The FCA’s Consumer Duty is designed to set a higher bar for the protection of retail customers, ensuring that firms act in customers’ best interests. Under this Duty, firms must take reasonable steps to ensure that products and services are fit for purpose, represent good value, and are appropriately targeted to their intended customers.
To comply with this, insurers, brokers, and MGAs must demonstrate that their products not only meet customer needs but are also priced fairly and accessible to the right audiences. In practice, this requires comprehensive and transparent reporting on how each product delivers value to the customer.
An example, a product sold to a 50 year-old motorist may offer a different value proposition compared to one sold to a 30 year-old. The fairness of these products must be evidenced, considering the specific needs of each customer segment. This data must be tracked, documented, and easily accessible for both internal review and external scrutiny from the FCA. This level of transparency is essential to show that fair value has been considered at every stage of the product lifecycle from development to sale.
Many firms continue to collect data in multiple, disconnected systems, making it difficult to consolidate, analyse, and compare the information effectively. This fragmented approach slows down decision-making and makes it harder to prove that each product offers fair value to its target audience.
In addition to the fragmented data issue, many insurance firms continue to rely on manual processes to meet regulatory requirements. While spreadsheets, emails, and traditional record keeping methods may have been sufficient in the past, they no longer meet the demands of the FCA’s Consumer Duty.
The process of manually tracking and reporting on fair value compliance is not only labour intensive but also prone to human error. The complexities involved in collating data from different sources, ensuring its accuracy, and generating comprehensive reports to the FCA are time consuming and prone to oversights. These manual tasks often result in firms missing critical compliance deadlines, which can carry serious consequences, including fines, reputational damage, and even legal action.
The reliance on outdated tools also limits a firm’s ability to spot trends, identify emerging risks, or adapt to changing customer needs in real time. In today’s competitive market, where speed and agility are critical, this can be a significant disadvantage.
Another significant challenge under the Consumer Duty is a lack of clarity in how firms define and understand their products’ target market and value proposition. Under FCA guidelines, firms must have a clear understanding of who their products are for, but many firms still provide vague or overly broad descriptions of their customer segments.
Without proper data analysis and targeted insights, it’s easy for firms to inadvertently sell products that don’t meet the needs of their customers or fail to provide the promised value. Moreover, if a firm can’t demonstrate that it has the right data and processes in place to track customer outcomes, it risks being perceived as non-compliant, which could lead to reputational harm and regulatory scrutiny.
The good news is that technology has a key role to play in helping firms meet the demands of the FCA’s Consumer Duty. Innovative tools, such as the one we’ve developed at Reg Technologies, can help firms automate the process of data collection, analysis, and reporting. These solutions are designed to overcome many of the challenges outlined above.
Meeting fair value obligations under Consumer Duty requires firms to evidence not just their own processes, but also how value is delivered across their entire distribution chain. That means gathering and assessing data from multiple counterparties — a task that can quickly become complex, inconsistent, and resource-heavy.
This is where REG Exchanges comes in. Built as a smart information exchange, Exchanges streamlines the way firms acquire, share, and analyse data across the market, making fair value assessments simpler, faster, and more robust.
With REG Exchanges, firms benefit from:
Standardised fair value assessment templates that ensure every counterparty provides information in the same format, making data easier to compare, analyse, and audit.
Exchanges enriches submissions with real-time regulatory data from the REG Network, adding context and assurance to every piece of information received.
Firms can capture and share data not only with direct partners but also across extended chains (e.g., your supplier’s supplier), giving a complete view of value across all parties involved.
All information shared through Exchanges is securely tracked, creating a transparent audit trail that can be downloaded into streamlined reports for internal governance or regulatory submission.
Exchanges continuously monitors submissions and counterparties, flagging gaps, risks, or changes that could impact fair value assessments before they escalate.
By turning a manual, fragmented process into a single, digital workflow, REG Exchanges gives firms the confidence that their fair value evidence is consistent, complete, and regulator-ready — while significantly reducing the operational burden.
The Future of Fair Value Compliance
As the FCA’s Consumer Duty continues to reshape the regulatory landscape, getting fair value compliance right is no longer optional it’s essential for long-term success. Firms that fail to adapt risk falling behind competitors, facing penalties, or losing customer trust. However, by embracing technology and automating compliance processes, firms can not only meet regulatory requirements but also improve efficiency, reduce risk, and enhance customer satisfaction.
At Reg Technologies, we understand the challenges that insurers, MGAs, and brokers face in navigating these regulations. Our innovative tool helps firms consolidate their data, automate compliance tasks, and ensure that they are meeting the FCA’s fair value expectations. With the right tools in place, firms can stay ahead of the curve and demonstrate their commitment to delivering fair value to customers now and in the future.
Fair value is here to stay and getting it right now will give firms a competitive advantage and protect their reputation in the long run.
Discover more about REG Exchanges or book a demo with our team today!
Access our insightful market briefing hosted by our Head of Customer Success Nathan Banfield, in collaboration with the Managing General Agents' Association (MGAA) to learn how RegTech enables insurers and MGAs to meet compliance expectations and stay ahead of regulatory changes.
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