Consumer Duty resources

Our approach to the paradigm shift in regulatory expectations.

What is the Consumer Duty?

The Consumer Duty is a set of new rules that are designed to ensure that firms in the financial services industry provide a higher standard of care to retail consumers.

Described by the Financial Conduct Authority (FCA) as a ‘paradigm shift’ in the UK financial services regulatory landscape, it asks firms to deliver good customer outcomes in four key areas:

Key dates

  • 31 July 2023 – implementation deadline for new and existing products and services that are open to sale or renewal
  • 31 July 2024 – implementation deadline for closed products and services 


FAQs for distributors

We have set up a cross-functional program across the various regulated businesses to implement Consumer Duty requirements within the regulatory timeframes, and ensure roles, responsibilities, processes, policies, procedures and governance are in place to support the requirements on an ongoing basis.  

Yes. Invesco has been regularly engaging with the Investment Association and other industry bodies. We are also in consistent communication with our partners to ensure our solution aligns with their requirements.

We have provided value assessment results for relevant investments as manufacturer by 30th April 2023. The scope of information covers the following products and services: 

·       ICVC funds

·       SICAV

·       ETF/ETCs

·       Investment Trusts

·       Discretionary MPS

We will use the European MiFID Template (EMT) as the key distribution mechanism to confirm Pricing Valuation Assessment outcomes for each of our products and are looking to produce and publish more detail around the Invesco approach imminently. We will also provide information in a similar format for products without an EMT e.g., Model Portfolio Service (MPS) which will leverage an EMT equivalent format where data will be available upon request. 

We have established a robust value assessment framework that ensures all our products provided fair value to retail customers in the target market.

We will conduct a value assessment for all products we are selling to retail customers into the UK (excl. ICVC which will leverage the existing value assessment as it is covered by COLL 6.6). We will take a consistent approach, where possible, across the different ranges to makes this process as simple as possible for our sub-distributors.

A more detailed methodology document is available to distributors upon request.

We are actively feeding into industry discussions on data interchange with distributors. Where we are waiting for that, we reasonably expect negative target market information to be provided via the distributor feedback inbox

No changes are anticipated.

Investment risks

  • The value of investments and any income will fluctuate (this may partly be the result of exchange rate fluctuations) and investors may not get back the full amount invested.

Important information

  • Where individuals or the business have expressed opinions, they are based on current market conditions, they may differ from those of other investment professionals and are subject to change without notice.