Consumer Duty guide
Consumer Duty affects how motor dealers think about customer understanding, fair value, support and evidence during the vehicle finance journey.
Can the customer understand the finance route, the dealer’s role, commission disclosure and what happens if a proposal is declined?
Can staff spot when a customer may need more time, clearer explanations or a different communication method?
Can the dealership show that complaints, feedback, file checks and customer outcomes are reviewed rather than left in separate inboxes?
Consumer Duty asks firms to consider customer outcomes across the products and services they provide.
For motor dealers, this often includes finance introductions and customer communications.
A dealership may update its finance page, change broker arrangements and train new sales staff at different times. A short compliance review helps check that the customer journey, website wording and staff process still match.
Customers should receive information in a way they can understand.
Dealers should consider whether finance wording, explanations and handovers are clear.
For example, if a customer asks whether the dealer is the lender, staff should be able to explain the credit broking role clearly and point to the right disclosure wording.
Customer understanding can also be affected by optional products. If paint protection, warranty, GAP-style products or other add-ons are discussed alongside finance, the customer should understand what is optional, what it costs and how it affects the overall deal.
Dealers should consider whether the customer journey supports fair value and suitable outcomes.
This does not mean guaranteeing outcomes, but it does require thoughtful processes.
A customer may focus on the monthly payment and miss the total amount payable, optional extras or product limitations. The finance journey should give customers enough information to make a considered decision.
Staff should know how to identify signs that a customer may need additional support.
The process should allow time and care where vulnerability may be present.
During a finance application, a vulnerable customer may need more time, simpler explanations, a trusted person present or a different communication method. Staff should know how to pause the process rather than pushing for a quick decision.
Commission disclosure should be clear and consistent with the firm’s arrangements.
Customers should not be left confused about the dealer’s role in the finance process.
If commission disclosure wording sits only in an old email template, sales staff may not know what the customer has been told. That is a practical Consumer Duty risk.
Complaints and feedback can show where customers are confused or unhappy.
Reviewing themes helps a dealer improve processes.
Complaints can show where customer understanding is weak. Repeated complaints about monthly payments, optional products, settlement figures or who arranged the finance should prompt a review of the customer journey.
Consumer Duty is easier to evidence when the firm keeps records of reviews, complaints, file checks and process updates.
Monitoring should be proportionate and practical.
Useful evidence may include file review notes, complaints themes, staff briefings, website review dates, vulnerable customer examples and changes made after feedback.
Consumer Duty should sit within wider ongoing compliance support, not as a separate one-off exercise.
For help, see our Consumer Duty support for motor dealers.
A customer agrees to a monthly payment but later says they did not understand an optional product was included. The dealer should be able to evidence how the option was explained.
A customer thinks the dealer is the lender, or does not understand the role of the broker. Clear role disclosure reduces this risk.
A customer becomes distressed or confused during the finance process. Staff should know how to slow the process and offer support.
Several complaints mention poor finance explanations. That should feed into monitoring, staff reminders and customer journey changes.
Consumer Duty can apply where motor dealers carry out regulated activity such as finance introductions.
Dealers should consider understanding, fair value, suitable support and whether customers can make informed decisions.
It affects how finance options, disclosures, commission information and customer support are handled.
Yes. Complaints and feedback can provide evidence about customer understanding and outcomes.
Yes. 009 Compliance can help motor dealers organise practical Consumer Duty records and monitoring.
These official FCA pages may help you check the current position before making decisions or submitting information.
We help motor dealers create practical compliance processes that support better customer outcomes.
This page provides general information only. It is not legal or regulatory advice. Firms remain responsible for checking their own FCA permissions, RegData schedule and reporting obligations.
