24 July 2023


    • New Guardian research with nearly 800 advisers gives insight into how the Duty is impacting their businesses and protection recommendations
    • 57% of advisers said they have made changes to the way they approach protection as a result of Consumer Duty

    According to new adviser research conducted by Guardian about the impact of Consumer Duty on the protection market, over 40% of advisers said they expected to make more protection recommendations as a result of the regulation. A further 58% expected their protection recommendations to stay the same, with only a small minority (1%) who said they expected to sell less protection.

    This positive adviser sentiment about the impact of Consumer Duty was also reflected in the overwhelming majority view that the regulation would result in a move by advisers towards value-led protection recommendations:

    • 84% agreed that with Consumer Duty’s emphasis on fair value, the portals and associated product analysis services will become a more important part of the selection process
    • 83% expect Consumer Duty to improve consumer experience of protection
    • 81% said that Consumer Duty will result in more advisers focusing on quality over price when selling protection

    The impact of Consumer Duty on adviser businesses
    The research quizzed advisers about how Consumer Duty was impacting their own businesses, and what changes if any they were making to comply. Responding to the survey, 62% said that the Consumer Duty was having at least a degree of impact, with 49% stating it was having ‘some’ or ‘reasonable’ impact, with another 13% stating the impact was ‘big’ or ‘very big’.

    When asked to rank which of the outcomes or cross cutting rules was having the biggest impact in terms of the changes being made to their firm, the 442 advisers who answered this question ranked ‘Consumer Understanding’ as number one. This was followed by ‘Price and Value’ in second place, and ‘Products and services’ in third. ‘Consumer support’ came next, followed by ‘Firms should act in good faith’, then ‘Firms should avoid foreseeable harm’, and bottom of the list in terms of the changes being made, was ‘Firms should help consumers achieve their financial objectives’, most likely reflecting that this is already well incorporated into their business and processes. See footnote 1.

    The survey also asked advisers to rank the area/function within their business that Consumer Duty was causing the bulk of the changes being made. Of the 429 responding here, advisers ranked ‘Advice processes’ at number one, followed by ‘Client communications’. ‘Documenting evidence’ came third, followed by ‘Partnerships’, including making protection referrals. Lower down the list, advisers ranked ‘Due diligence of their recommendation’, ‘Fees charged’ and ‘IT processes’ respectively in terms of the areas/functions where changes were being made because of Consumer Duty. See footnote 2.

    35% of advisers said they’d made significant changes to their website. Advisers were also asked whether across the market, providers communication to date was clear and useful enough to equip them to comply with the Duty, with 89% of them answering yes.

    Jacqui Gillies, Guardian Marketing and Proposition Director, said: “It’s great to have so many advisers give us their view on Consumer Duty and even better to hear that the regulation is having a positive impact – not just on the customer but on the protection industry as a whole. The fact that over 40% of advisers said they expect it to lead to them making more recommendations will mean more customers getting the protection they need.

    “It’s also encouraging to know that advisers are taking the Duty seriously and making changes to their businesses where they feel they have potential to further improve outcomes for consumers. Knowing that 83% of advisers expect the Duty to improve the consumer experience of protection is, I think, a massive boost for our industry in the current climate.

    “Having carried out our own analysis within Guardian, we appreciate the time and effort needed to be ready for the new regulation coming in at end of July so it’s good that the vast majority of advisers believe the information from providers is clear and useful – and will allow them to comply with the Duty. Advisers can find more information on Guardian’s target markets and fair value assessments on our website.

    Commenting on the findings, Roy Mcloughlin, Cavendish Ware Director of Strategic Partners, said: “Whenever new regulation comes along, the workload and costs associated with the changes are often well documented. So it’s really good to see Guardian’s research findings show that when it comes to Consumer Duty, the majority of advice firms agree that it will lead to an improved consumer experience of protection, and also for many, an expectation that they will make more protection recommendations.”

    -Release ends-

    Notes to editors:

    Research with 796 advisers conducted by Guardian between 11 June and 7 July 2023.

    Press enquiries to Natalie Robinson, 07789 501146,

    Footnote 1: Which of the Consumer Duty outcomes / cross cutting rules are resulting in the biggest changes being made to your firm? (Please rank from 1 to 7 in terms of impact/workload. 1- the biggest change; 7- the smallest change)

    Footnote 2: Related to the ranking above, in which area/function are the bulk of the changes being made to your firm? (Please rank from 1 to 8. 1- the biggest change; 8- the smallest change)

    Guardian Financial Services is an appointed representative of Scottish Friendly Assurance Society Limited which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority.

    All products are provided by Scottish Friendly Assurance Society Limited and we have an agreement with them to underwrite and issue the protection policies we distribute through the UK intermediary channel.

    As an appointed representative of Scottish Friendly Assurance Society Limited, Guardian Financial Services Limited is the market-facing brand under which we promote our proposition and engage with advisers.

    Background to Guardian Financial Services, owned by Gryphon Group Holdings

    Guardian, the life and protection insurance business, launched in 2018 and pledged to grow the protection market. The brand promise of ‘Life. Made Better.’ reflects the company’s commitment to rethink and reinvent protection for the better; making sure customers get cover that’s easier to understand, simple to buy and designed to never let them down.

    Guardian’s business partners

    Gryphon Group Holdings is majority owned by Punter Southall Group as the largest equity capital investor. Guardian partners with UnderwriteMe for its Underwriting Engine, Liss Systems, the UK arm of Nasdaq-listed EXL, for its policy administration technology, and Space, for its front end technology, branding and marketing. Guardian’s reinsurance partners are Hannover Re and Gen Re.