Move TCF from a compliance checkbox to an operational reality — with practical frameworks for monitoring, evidencing, and improving fair customer outcomes.
Treating Customers Fairly (TCF) has been a cornerstone of FCA regulation since 2007, rooted in Principle 6 (treating customers fairly) of the FCA's Principles for Businesses. The FCA defined six consumer outcomes that firms should deliver — covering confidence, products, information, advice, service standards, and barriers to switching. Yet nearly two decades later, many insurance firms still struggle to demonstrate that TCF is genuinely embedded in their operations.
The introduction of Consumer Duty in 2023 raised the bar further. While TCF asked firms to treat customers fairly, Consumer Duty requires them to act to deliver good outcomes. The FCA has been explicit that Consumer Duty builds on and goes beyond TCF. Firms that were already delivering strong TCF outcomes found the transition manageable; those with superficial TCF frameworks found significant gaps.
The core challenge remains the same: how do you translate high-level principles into measurable, monitorable operational practices? Without clear metrics, defined responsibilities, and systematic monitoring, TCF becomes a statement of intent rather than a demonstrable business practice.
Embedding TCF requires translating each of the six consumer outcomes into specific, measurable indicators that can be tracked across your business operations. For an insurance firm, this means defining what "fair treatment" looks like at every customer touchpoint — from product design and marketing, through the sales and advice process, to claims handling and complaints resolution.
The framework must connect TCF monitoring to your governance structures. Board-level MI should include TCF outcome metrics alongside financial performance data, and there should be clear escalation routes when metrics indicate that customers may not be receiving fair treatment. Under Consumer Duty, this is no longer optional — PRIN 2A.2 requires firms to monitor and regularly review outcomes.
Critically, TCF must be embedded in culture, not just process. This means training, incentive structures, and performance management that reinforce fair customer outcomes. The FCA has consistently emphasised that culture is the most important driver of TCF — firms that treat it as a compliance exercise rather than a cultural imperative will always fall short.
Follow these steps to move TCF from a policy document to an operational reality, with clear metrics, governance, and cultural reinforcement.
Take each of the six FCA TCF outcomes and map them to specific stages of your customer journey. For example, Outcome 2 (products designed to meet the needs of identified consumer groups) maps to your product design and governance process; Outcome 5 (consumers not facing unreasonable post-sale barriers) maps to your claims handling and policy servicing processes. This mapping creates the foundation for targeted monitoring.
For each TCF outcome, define 3-5 specific, measurable indicators. Examples include: claims acceptance rates and average settlement times (Outcome 5), complaints volumes by product and root cause (Outcomes 3 and 4), customer satisfaction scores by journey stage (Outcome 6), and product take-up versus target market (Outcome 2). Ensure indicators are based on data you can actually collect consistently.
Before you can monitor improvement, you need to know your starting point. Collect baseline data for each indicator and set realistic improvement targets. Be transparent about areas where current performance is weak — the FCA values honesty and a credible improvement plan over a facade of perfection.
Create a regular TCF outcomes report for the board or executive committee. This should present the key indicators, trend analysis, any areas of concern, and actions being taken. Under Consumer Duty, the board must review and approve an annual outcomes assessment — embedding TCF MI into existing governance is the most efficient way to meet this requirement.
Review your incentive structures — including staff bonuses, intermediary commissions, and sales targets — to ensure they do not create conflicts with fair customer outcomes. Under SYSC 19F (the remuneration code for insurance intermediaries) and Consumer Duty, incentive arrangements must not encourage behaviour that is detrimental to customers. Include TCF metrics in individual performance assessments.
Design training that goes beyond generic awareness. Front-line staff need practical guidance on what TCF means in their specific role: how to identify vulnerable customers, how to present information clearly, when to escalate concerns. Claims handlers, underwriters, and complaints teams each need role-specific TCF training.
Supplement your monitoring metrics with qualitative testing: mystery shopping, file reviews, call listening, and customer interviews. These methods reveal aspects of the customer experience that quantitative data alone may miss — such as the tone of communications, the clarity of explanations, and the ease of processes.
Map your TCF framework directly to the four Consumer Duty outcomes: products and services, price and value, consumer understanding, and consumer support. This avoids duplication and ensures your monitoring covers both the legacy TCF outcomes and the new Consumer Duty requirements in a single, coherent framework.
The FCA is interested in what customers actually experience, not just what your processes say should happen. A well-documented process that consistently produces poor outcomes is worse than an informal process that delivers good results. Always validate process compliance against actual customer outcomes.
Assess TCF outcomes specifically for vulnerable customers, not just the general customer population. Under Consumer Duty, firms must deliver good outcomes for all customers, including those with characteristics of vulnerability. Segment your data to identify whether vulnerable customers experience different outcomes.
TCF should not be owned solely by the compliance team. Every function — from product design to claims to IT — contributes to customer outcomes. Embed TCF champions in each department and ensure that TCF is a standing item in team meetings and project planning.
Complaints and FOS outcomes are the most direct measure of where TCF is failing. Analyse every upheld complaint and every FOS decision against your firm to identify the specific point in the customer journey where fair treatment broke down, and take targeted corrective action.
3-5 specific metrics per outcome, based on consistently available data.
Regular reporting covering indicators, trends, concerns, and remedial actions.
Mystery shopping, file reviews, and call listening conducted regularly.
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complaints handlingStructured processes ensure complaints from vulnerable customers receive the enhanced care, flexibility, and support that the FCA expects under its vulnerability guidance and the Consumer Duty.
claims managementFirst Notification of Loss sets the tone for the entire claim. Get it right and you accelerate every downstream process; get it wrong and costs compound at every stage.
SwiftCase helps insurance firms track TCF indicators, generate board-level MI, and embed fair treatment across every customer touchpoint.
