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Consumer Duty launches

Updated January 2024

The Financial Conduct Authority (FCA) published its Policy Statement and Final Guidance for the new Consumer Duty regulation in July 2022, a year ahead of its introduction. AXA Health has been working to prepare for the higher standard of customer care for some time, and now Consumer Duty is live, we wanted to provide you with a brief update. 

As a company that already has the customer at the heart of our business strategy, AXA Health welcomes the higher standards of customer protection. We believe it will be good for our business as we continue to deliver the best outcomes for our customers.    

A reminder of the requirements 

Consumer Duty introduces a new principle for firms to ‘act to deliver good outcomes for retail customers’ at every stage of the customer journey, which is supported by three cross-cutting rules. The higher standards seek to improve outcomes across the customer journey and requires firms to be able to understand and evidence how these are being met.

Consumer Principle A firm must act to deliver good outcomes for retail customers
Cross-Cutting Rules 1. Act in good faith 2. Avoid causing foreseeable harm 3. Enable and support retail customers to pursue their financial objective
Consumer Outcomes 1. Product and Services 2. Price and Value 3. Consumer Understanding 4. Consumer Support

As an independently authorised distributor of our products, you will have your own responsibilities under the Consumer Duty. More information about the regulation can be found on the FCA’s Consumer Duty page.

How we have responded

Where we have identified opportunities to enhance our customer outcomes we have taken action. Some of these focus areas are included below:

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Customer Service

Call wait times have been a strong focus with continued improvements in the time to answer customer enquiries. Processes have been reviewed to ensure we are delivering good outcomes for our customers, including those displaying characteristics of vulnerability.



Customer communications have been reviewed and updated to support customer understanding. Examples of changes include the addition of signposting to help customers that are impacted by the cost-of-living crisis plus the provision of refreshed renewal FAQs for individual customers and renewal FAQs for SME customers. These FAQs now cover why premiums might increase and provide advice on how to reduce premiums if they do.  We’ve also launched a customer insights and customer outcomes dashboard to better understand how our customers experience our products and services, with actions taken on specific pain points, if required.

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Product value

Our products and services have been reviewed to assess whether they remain consistent with the needs of the target market, the distribution strategy remains appropriate, and the product provides fair value for the customer. The results of these are available here and will be updated at least annually. Please ensure you read the Target Market Statements which will help in understanding the target market and expected distribution strategy for our products.


Vulnerable customers

We have made system upgrades to ensure our customers only need to tell us about customised support needs once, regardless of the systems our agents are using. This has also been supported by enhanced processes, training and governance.

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Staff Training

Training has been rolled out to staff to make Consumer Duty requirements clear including front line teams, support functions and senior management.

Take a look at our updated FAQs, which we’ve refreshed to reflect some of the queries we’ve received from our brokers. If you have any further queries, please contact your account manager.   


We have a range of measures in place to ensure fair value is delivered through our products and services, including product oversight reviews available here.  

We’ll need your continued help to recognise vulnerable customers during your interactions. This means identifying any customised support or reasonable adjustments the customer may need. More information on how to treat vulnerable customers has been published by the FCA.

Following its recent consultation, the FCA has published final guidance on how firms should support customers in financial difficulty, effective from 31st July 2023. This relies on identifying indicators of financial difficulty, effective signposting to options available, and ensuring all relevant options are explored to reduce, as far as reasonably possible, the risk of the customer losing appropriate cover that is important to them.

Unfortunately, AXA Health is not able to share the Vulnerable Customer policy or any other internal policies with its brokers. However, our policies have been reviewed and updated to make sure that we are meeting the requirements of Consumer Duty. In this way we hope to deliver good outcomes for customers and ensure that foreseeable harm is avoided.

The FCA has published information on all aspects of the new Consumer Duty on its website.