Client experience in the Consumer Duty era — what changed and what's worth doing

For a long time, "client experience" was a marketing department's word — the bit between brand and operations that nobody owned. A nicer welcome pack here, a quarterly newsletter there, maybe a Christmas card if the firm was feeling sentimental.

That ended in July 2023. Consumer Duty's four outcomes — products and services, price and value, consumer understanding, consumer support — made the client's experience of the firm a regulated obligation. Two of those outcomes (understanding and support) are directly about how the firm engages with the client. The other two are reachable only through the engagement.

What this means in 2026, year-2 of supervision: the soft-edged version of client experience is no longer enough. The firm has to evidence it.

What the FCA actually wants to see

Across the FCA's published Consumer Duty supervisory letters, the multi-firm reviews, and the year-1 board-report feedback, three patterns are clear about what "good" client experience evidence looks like:

Response time, by client segment.How long does it take the firm to answer a client query? Segmented by service tier, by query type (admin versus advice), and ideally over time. A firm that can produce that view in a board meeting is in a stronger supervisory position than one that hand-waves at "we're responsive".

Comprehension evidence on key documents.Suitability reports, fair-value disclosures, the year-end review pack. The Consumer Understanding outcome asks the firm to demonstrate that communications work — that the client could and did understand what they signed. That's harder than it sounds. The firms doing it well have built lightweight comprehension checks into the client journey: a confirmation question after a key disclosure, a recorded conversation where the client repeats back what they understood, a clear note in the file.

Vulnerable-client adaptation data.Year 2's heaviest evidence ask. What proportion of the book has been assessed for vulnerability characteristics? What was found? What adaptations followed? A firm with no number here is in trouble. A firm with a number but no follow-up actions is in different trouble.

Ongoing-review completion against schedule.Did the firm do what it said it would do, in the timeframe the client agreed to? The Consumer Support outcome is partly about the standing service the client is paying for actually showing up.

None of these are new ideas. What's new is that the firm is expected to produce the evidence on demand, not assemble it during a Section 165 information request.

The gap between what clients perceive and what the firm can show

Most IFA firms have always cared about how their clients experience the service. The Christmas card is sincere. The follow-up calls are sincere. The relationship is real. The problem in 2026 is that sincerity isn't auditable. The FCA's expectation isn't "the firm thinks it has good client outcomes". It's "the firm can show, with data, that it does".

That's where the soft-edged version of client experience meets the operational reality. The firms that close the gap are the ones with:

• A CRM that captures every client interaction — including the informal ones — in a way that's queryable later.
• A defined service-tier schedule that the system actually enforces, rather than a document on the shared drive that drifts away from real practice.
• A complaint-and-feedback channel that gets used, with logged outcomes — not a satisfaction score and a vibe.
• A vulnerable-client review process that runs on a cadence, not in response to an audit.

The technology piece is enabling, not central. The central piece is that the firm has decided what good client experience means for it, written it down, built a system that measures it, and looks at the measurements regularly enough to act on them.

What "good" looks like in 2026 — three patterns

1. The service-tier schedule that's actually on rails

Most firms have three service tiers — say Platinum, Gold, Silver — with different contact and review frequencies. Most firms drift on the schedule under load. The firm gets busy, a Silver client gets bumped, and six months later the client has had no contact and the firm has no record of having decided that's OK.

The firms doing this well let the system enforce the schedule. The client's tier dictates the cadence. Missed touchpoints generate alerts. The annual board review shows the actual versus scheduled contact rate by tier, which is exactly the evidence the FCA wants to see on Consumer Support.

2. The proactive contact, not the reactive one

Under Consumer Duty, reaching out before the client needs to ask is worth more than reaching out after. A market wobble that affects a particular client segment — a heavy Russian equities allocation, a sterling weakening, a sector concentration — should generate a "we're aware, here's what it means for your portfolio" note to the affected cohort, not an inbox of client queries that the firm scrambles to answer.

The mechanism: the firm runs cohort analysis across the book — by holding, by segment, by vulnerability flag — and triggers communications when the cohort moves materially. The technology has been within reach for a while; the operational discipline to use it is what makes the difference.

3. The vulnerable-client adaptation that's documented

The year-2 supervisory ask. Across most firms we've worked with, the vulnerability assessment is happening — but the documentation of what changed afterwards is uneven. A client identified with a hearing impairment should have an adaptation recorded — extended meeting time, written follow-up of every verbal discussion, a different communication channel. The firm should be able to pull that cohort and show the adaptation in seconds.

A firm that's invested in this is in a different supervisory conversation in 2026 than a firm that hasn't. The investment isn't large. The lapse is unnecessary.

The client side — what they actually want

The Consumer Duty framing is regulatory. The client framing is human. Both matter, and they overlap more than they diverge.

Across the client-experience research that's available — Boring Money's adviser studies, the Lang Cat's platform work, the trade-body member surveys — the consistent themes from clients are:

• "I want to know what's going on without having to ask."
• "When I do ask, I want a quick, clear answer."
• "I want to feel like the adviser knows me — not just my portfolio."
• "When something significant happens in the markets, I want a heads-up before I see it on the news."

Those are not exotic asks. They're the same things the Consumer Support outcome is asking the firm to evidence. Done right, "good for the regulator" and "good for the client" are the same thing.

What an IFA firm can do this quarter

Four practical asks, in priority order:

First, run a service-tier audit. For the last 12 months, what proportion of each tier's clients got the contact and review cadence the tier promised? If the answer for any tier is below 90%, the firm has a Consumer Support evidence gap and a client-relationship gap at the same time.

Second, run a vulnerable-client documentation audit. Pick 20 clients identified as having vulnerability characteristics. Can the firm show, for each, what was identified, what adaptation followed, and when the adaptation was last reviewed? If the answer for any is "we know but we didn't write it down", that's where the year-2 work goes.

Third, look at response times. How long does it take the firm to answer a client email? A phone call? A portal message? Aggregate, by tier, over time. The firm doesn't need a dashboard. It needs a number it trusts.

Fourth, pick one cohort communication the firm could send in the next month that the book isn't expecting. Run the cohort. Send the note. Log the responses. That's both the year-2 Consumer Support evidence and the kind of contact that builds the relationship.

Where Wealth Analytica fits

Wealth Analytica's practice-management viewties the service-tier schedule, the cohort analysis, the vulnerable-client cohort data, and the response-time metric into one place — so what the firm wants to do for its clients and what the firm has to evidence for the regulator come out of the same record, not two different scrambles.

Client experience under Consumer Duty isn't about being warmer than the firm next door. It's about being able to show the warmth happens, on schedule, for everyone the firm is paid to look after. The firms that can do both win the regulatory conversation and the retention conversation at the same time.