Fair Value & Consumer Duty
in Insurance

Fair Value and Consumer Duty have become central priorities for insurers, brokers and MGAs operating within the UK insurance market. Firms are increasingly expected to demonstrate that products deliver fair customer outcomes, maintain appropriate oversight and evidence value throughout the distribution chain.
 
 
This guide explores Fair Value and Consumer Duty requirements within insurance, including governance expectations, operational challenges and the growing role of RegTech in supporting compliance oversight.

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What is Fair Value?

Fair Value refers to the FCA expectation that insurance products provide reasonable value to customers relative to the price paid and the benefits received.

Insurance firms are expected to assess:

  • Product value
  • Pricing structures
  • Distribution arrangements
  • Customer outcomes
  • Fees and commissions
  • Product suitability

This forms a key part of the wider Consumer Duty framework introduced by the FCA.

What is Fair Value?
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Understanding Consumer Duty for Insurers and MGAs

Consumer Duty is designed to raise standards of customer protection across financial services and insurance markets.

The FCA expects firms to:

  • Act to deliver good customer outcomes
  • Avoid foreseeable harm
  • Support customer understanding
  • Demonstrate effective governance and oversight
  • Monitor product performance appropriately

For insurers, brokers and MGAs, this requires stronger visibility across the full product lifecycle and distribution chain.

Why Fair Value Matters in Insurance

Fair Value assessments have become a major operational focus across the insurance industry, particularly where firms operate through delegated authority structures, complex distribution chains or with counterparty risk management.

Insurance firms are increasingly expected to evidence:

  • How products deliver value
  • How pricing decisions are assessed
  • How customer outcomes are monitored
  • How distributors are overseen
  • How governance decisions are documented

This has increased pressure on firms to improve visibility, reporting and operational oversight across product governance processes.
 
 
 
 
 
 
 
 

Fair Value Compliance Challenges

Many insurance firms continue to face operational challenges when gathering, analysing and evidencing Fair Value data across multiple counterparties and distribution channels.

  • Data Collection Challenges

    Gathering consistent product and distribution data across multiple parties.

  • Oversight Complexity

    Managing visibility across delegated authority and distribution arrangements.

  • Governance Documentation

    Maintaining clear records of reviews, decisions and oversight activity.

  • Outcome Monitoring

    Demonstrating that products continue to deliver fair customer outcomes.

  • Operational Efficiency

    Reducing manual administration linked to Fair Value reviews and reporting.

  • Regulatory Scrutiny

    Preparing for increased FCA expectations around evidence and governance.

How REG Supports Fair Value Governance

REG Technologies helps insurers, brokers and MGAs improve Fair Value governance, streamline compliance oversight and reduce operational complexity through purpose-built RegTech solutions.

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RegTech workflows supporting MGA compliance oversight

Data, Governance and Oversight

Fair Value compliance depends heavily on operational visibility and structured governance processes.

Firms increasingly need to:

  • Centralise compliance data
  • Evidence product reviews
  • Monitor distributor relationships
  • Maintain audit trails
  • Document governance decisions
  • Support board-level oversight

As regulatory expectations evolve, many organisations are investing in technology and operational frameworks that improve consistency across Fair Value and Consumer Duty processes.

How RegTech Supports Fair Value Compliance

RegTech solutions are helping insurance firms manage the growing operational demands associated with Consumer Duty and Fair Value oversight.

  • Centralised Oversight

    Improve visibility across products, distributors and governance activity.

  • Automated Workflows

    Reduce manual administration linked to reviews and approvals.

  • Audit Readiness

    Maintain structured records and evidence for regulatory oversight.

  • Data Management

    Consolidate Fair Value information into a single operational environment.

  • Governance Tracking

    Support board reporting and compliance accountability processes.

  • Ongoing Monitoring

    Monitor customer outcomes and operational risks more consistently.

How REG Exchanges Supports Fair Value & Consumer Duty Oversight

Fair Value and Consumer Duty requirements have increased pressure on insurers, brokers and MGAs to maintain greater visibility across insurance distribution chains.

For many firms, one of the biggest operational challenges is not simply gathering documents or completing reviews. It is understanding how counterparties, delegated relationships and downstream entities connect across the wider distribution ecosystem.

REG Exchanges was designed specifically to help regulated insurance firms improve oversight, transparency and operational control across these complex trading relationships.

Built for Distribution Chain Visibility


REG Exchanges enables insurers, brokers and MGAs to improve oversight across insurance distribution chains by connecting counterparties, workflows and compliance activity within a centralised operational environment.


Rather than relying on fragmented spreadsheets, email chains and manual document requests, firms can maintain greater visibility across counterparties, downstream entities and delegated relationships involved in product distribution.


This helps organisations strengthen Fair Value and Consumer Duty governance processes by improving transparency, supporting audit readiness and simplifying oversight responsibilities across the wider supply chain.

REG Exchanges Distribution Chain Visibility

REG Exchanges Supports:

Distribution chain visibility

Improve visibility across counterparties, delegated relationships and downstream entities.

Centralised compliance oversight

Manage documentation, approvals and oversight activity within one operational environment.

Audit-ready governance

Maintain clearer records of reviews, attestations and compliance workflows.

Automated oversight workflows

Reduce manual administration linked to Fair Value and Consumer Duty processes.

Supply chain transparency

Support more effective oversight across complex insurance distribution structures.

Webinar: Cracking the Chain – RegTech’s Role in Fair Value Compliance

Fair Value compliance continues to create operational and governance challenges across the insurance distribution chain, particularly where firms rely on multiple counterparties and delegated authority arrangements.

This webinar explores how RegTech solutions can help insurers, brokers and MGAs improve visibility, strengthen oversight and simplify Fair Value compliance processes through better governance and operational efficiency.

Topics include data collection challenges, oversight responsibilities, Consumer Duty expectations and the growing role of technology in supporting ongoing compliance monitoring.

Watch Webinar   Browse More Webinars

Fair Value Blog

The Future of Fair Value & Consumer Duty

Fair Value and Consumer Duty are expected to remain long-term regulatory priorities across the UK insurance market.

As regulatory scrutiny increases, firms are likely to focus more heavily on:

  • Operational transparency
  • Governance accountability
  • Product oversight
  • Customer outcome monitoring
  • Audit readiness
  • Scalable compliance operations

Technology-enabled oversight models are increasingly becoming part of how firms manage evolving compliance expectations efficiently.

Fair Value Resources and Guidance

Explore the operational and governance challenges associated with Fair Value compliance, including data visibility, oversight complexity and regulatory expectations within insurance distribution chains.

Mastering Fair Value: How RegTech Solutions Tackle Assessment Challenges

As the July 31st deadline for Consumer Duty board reports approaches, effective reporting on assessment processes and positive consumer outcomes has never been more critical. The FCA states that fair value is the biggest challenge under the Consumer Duty, with firms managing diverse product lines and extensive distribution channels encountering heightened difficulties in gathering and processing data. Establishing a robust system capable of continuously requesting, acquiring, and analysing data from any size distribution network is essential for conducting thorough assessments. Those still reliant on emails and spreadsheets, rather than specialised digital solutions, find it challenging to manage these tasks effectively...

Learn more: Mastering Fair Value: How RegTech Solutions Tackle Assessment Challenges
Ella Olamona is an Marketing Executive at REG Technologies

Fair Value Compliance in the Insurance Sector: Tackling the Data Challenges

The UK insurance sector is facing a significant shift in how it approaches consumer protection and fairness. The introduction of the FCA’s Consumer Duty has set a new regulatory standard for insurers, Managing General Agents (MGAs), brokers, and other distributors. Central to this is the concept of fair value a principle designed to ensure that financial products meet the needs of the customers they’re sold to, and that consumers are protected from poor value or unnecessary costs. For many firms, however, implementing fair value standards is far from straightforward...

Learn more: Fair Value Compliance in the Insurance Sector: Tackling the Data Challenges
Mark Atkins, Head of Partnerships at REG Technologies

Setting the Standard for Fair Value Compliance with RegTech

Ensuring fair value for consumers has become a central concern for insurance firms. Regulatory bodies, such as the UK's Financial Conduct Authority (FCA), have increased their focus on fair value assessments to ensure that products and services genuinely benefit consumers relative to their costs. This heightened scrutiny has prompted insurers and Managing General Agents (MGAs) to reassess their practices, resulting in significant operational challenges. 

Learn more: Setting the Standard for Fair Value Compliance with RegTech
Zoë Parsons, Head of Marketing at REG Technologies

Mastering Fair Value: How RegTech Solutions Tackle Assessment Challenges

As the July 31st deadline for Consumer Duty board reports approaches, effective reporting on assessment processes and positive consumer outcomes has never been more critical. The FCA states that fair value is the biggest challenge under the Consumer Duty, with firms managing diverse product lines and extensive distribution channels encountering heightened difficulties in gathering and processing data. Establishing a robust system capable of continuously requesting, acquiring, and analysing data from any size distribution network is essential for conducting thorough assessments. Those still reliant on emails and spreadsheets, rather than specialised digital solutions, find it challenging to manage these tasks effectively...

Learn more: Mastering Fair Value: How RegTech Solutions Tackle Assessment Challenges
Ella Olamona is an Marketing Executive at REG Technologies

Consumer Duty Challenges for Insurers: A 2026 Guide

The Consumer Duty, enacted by the UK’s Financial Conduct Authority (FCA) on July 31st, 2023, represents a pivotal regulatory shift, mandating firms to prioritise customer interests and elevate outcomes. Applicable to all entities regulated by the FCA, spanning insurance firms, banks, and investment companies, the Duty extends across the spectrum of products and services offered to individual consumers and micro-enterprises. Since enforcement, adherence to the Duty has brought forth an array of challenges for firms subject to the new rules. With regulators imposing strict scrutiny, let’s explore the challenges around compliance with the Duty and how firms can overcome them...

Learn more: Consumer Duty Challenges for Insurers: A 2026 Guide
Zoë Parsons, Head of Marketing at REG Technologies

Frequently Asked Questions

What is Fair Value in insurance?

Fair Value refers to the FCA expectation that insurance products provide reasonable value relative to the price paid and the benefits delivered to customers.

What is Consumer Duty?

Consumer Duty is an FCA regulatory framework designed to improve customer outcomes and raise standards of consumer protection across financial services.

What does Consumer Duty mean for MGAs?

MGAs sit between insurers and customers, so they carry Consumer Duty obligations on both sides. That means evidencing product value in the schemes they underwrite, overseeing their own distributors, and sharing outcome data with capacity providers. Most MGAs find the reporting burden, rather than the principle, is what stretches existing resource.

Why is Fair Value important for insurers and brokers?

Insurance firms are expected to evidence that products deliver fair customer outcomes and that governance processes effectively monitor value across the distribution chain.

What challenges do firms face with Fair Value compliance?

Many firms face challenges around data collection, governance oversight, operational visibility and evidencing compliance activity across multiple counterparties.

How often should Fair Value assessments be reviewed?

The FCA expects assessments to be kept current rather than repeated to a fixed calendar. In practice most firms review annually as a baseline and re-assess sooner when pricing, commission structures, claims ratios or distribution arrangements change materially. The trigger should be a change in the product or the chain, not the date.

How can RegTech support Consumer Duty compliance?

RegTech solutions can help centralise compliance data, automate governance workflows and improve operational oversight linked to Fair Value and Consumer Duty requirements.

What does the FCA expect from insurance firms?

The FCA expects firms to act to deliver good customer outcomes, avoid foreseeable harm and maintain effective governance processes supporting Consumer Duty obligations.

Who falls under Consumer Duty?

Consumer Duty applies to FCA-authorised firms that determine or materially influence outcomes for retail customers. That includes insurers that design products and the brokers and MGAs that distribute them, even where they have no direct contact with the customer. Firms in a distribution chain share responsibility for outcomes.

What are the four outcomes of Consumer Duty?

The FCA sets four outcomes: products and services that meet customer needs, price and value that is fair, customer understanding through clear communication, and customer support that is effective throughout the relationship. Firms must monitor and evidence each one, which for insurers depends on good data from their distribution chain.

Strengthen Fair Value Oversight Across Your Insurance Operations

REG Technologies helps insurers, brokers and MGAs improve Fair Value governance, streamline compliance oversight and reduce operational complexity through purpose-built RegTech solutions.

Book a Demo