Where the Role Comes From

The Consumer Duty, part of the FCA’s Principles for Businesses, requires firms to act to deliver good outcomes for retail customers. When the FCA finalised the Duty, it said it expected firms to appoint, where appropriate, a champion at board level, ideally a non-executive director, to support the chair and chief executive in raising the Duty regularly in board discussions and challenging the firm on how it embeds the Duty.  See our crowdfunder campaign

It’s an expectation, not a Senior Manager Function or Prescribed Responsibility. The champion doesn’t need separate regulatory approval for the role, and accountability for the Duty stays with the board and the relevant Senior Managers. Our article on the Consumer Duty and the SMF framework explains where that accountability sits.

What the Champion Actually Does

• Keeps the Duty on the agenda, making sure customer outcomes are discussed regularly, not just at the annual assessment.
• Challenges the evidence. Asks whether management information really shows good outcomes, including for vulnerable customers.
• Tests decisions on products, pricing and distribution against the Duty’s outcomes.
• Supports the annual board assessment of whether the firm is delivering good outcomes, and challenges its conclusions.
• Connects with the business, often meeting customer-facing teams, compliance and complaints functions.
• Champions, but doesn’t own, the Duty. The board and executive remain responsible.

Who Should Take It On

Ideally an Independent Non-Executive

The FCA’s preference for a non-executive reflects the role’s purpose: independent challenge. An executive champion can find it hard to challenge decisions they’ve been part of.

Someone With Relevant Experience

The best champions understand retail customers, product design, pricing or complaints, and can read outcome data critically. Experience in a retail financial services business, consumer protection, or customer experience roles is valuable.

Someone With Time

The role adds to a non-executive’s workload: reading outcome reports, meeting teams, preparing for the annual assessment. Check they can absorb it alongside committee work.

Not Necessarily the Chair

The chair leads the board’s overall approach, so giving them the champion role too can reduce challenge. Some smaller boards do it, but a separate non-executive is usually better.

How It Fits With Senior Manager Responsibilities

The champion’s role complements, rather than replaces, these responsibilities. Where a firm has allocated a specific responsibility for the Duty to a Senior Manager, the champion and that Senior Manager should work closely together.

Signs Your Board Needs a Different Champion

• Consumer Duty discussions are limited to the annual assessment.
• The champion rarely challenges management information.
• Board papers on outcomes are accepted without questions about vulnerable customers.
• The champion has no retail customer experience.
• The role was allocated by default rather than by choice.

A board skills matrix is a quick way to check whether anyone on the board has the experience the role needs.

If No One on the Board Fits

Some boards, particularly smaller ones or those dominated by group executives, have no one well suited to the role. Options include:

• Recruiting an independent non-executive with retail and customer outcomes experience. NED Capital, a sister practice of SMF Capital, specialises in non-executive appointments.
• Training an existing non-executive, with support from compliance and external advisers.
• Combining the role with a committee chair position when recruiting a new risk or audit committee chair. Our page on chair and committee chair recruitment covers those Senior Manager appointments.

Our page on non-executive directors at FCA-regulated firms explains when a non-executive role needs regulatory approval.

Smaller Firms

At smaller firms with few or no non-executives, the champion may be a director who also has executive responsibilities. That can work if the firm builds in independent challenge in other ways, for example through an external review of its outcome monitoring.

Making the Role Work

Recording the Champion’s Work

Board minutes should show the champion’s contributions: questions asked, challenges made and actions agreed. If the regulator later asks how the board oversaw the Duty, a record of real challenge from the champion is strong evidence. Minutes that show the Duty was “noted” at each meeting, with nothing more, suggest the role isn’t working.

The Champion and the Annual Assessment

Each year the board must review an assessment of whether the firm is delivering good outcomes for retail customers. The champion should be closely involved in shaping that report before it reaches the board: what data it uses, whether it looks honestly at outcomes for different groups of customers, and whether it sets out what the firm will change. A champion who first sees the report in the board pack has arrived too late to make much difference. The best champions also follow up after the assessment, checking that the actions it identifies are delivered and reported back to the board during the year.

Frequently Asked Questions

Is the Consumer Duty champion a Senior Manager Function?

No. It’s an FCA expectation rather than a Senior Manager Function or Prescribed Responsibility, and doesn’t need separate approval.

Does every firm need a champion?

The FCA expected firms to appoint one where appropriate. Most firms with retail customers and a board of any size have one.

Can an executive be the champion?

It’s possible, particularly at small firms without non-executives, but an independent non-executive is generally preferred because the role is about challenge.