Delivery of implementation plans to the board (or equivalent management body) in October will have been a checkpoint for firms to gather and act on important feedback from board members on the robustness of plans. For most, this will have been the culmination of significant planning work across the business, product and servicing teams to determine the uplifts and changes required.

From November onwards, project teams will continue to move forward with implementation. Time should be taken to reflect any changes needed as a result of Board feedback to plans, identify and address potential risks to delivery and ensure project governance is in place to support successful delivery. This is likely to include:

• Communicating and ensuring roles and responsibilities are understood
• Establishing and embedding delivery and progress management forums
• Developing reporting and MI for monitoring and escalation
• Identifying conflicts or bottlenecks due to BAU activities and or other change activity
• Creating greater visibility of dependencies and downstream impacts in respect of third parties, partners and technology

Putting the above into context, ensuring clarity on roles and responsibilities is key to being able to demonstrate the project has the appropriate ownership, accountability and direction. This ensures that the attendees of management forums and/or steering committees have sufficient knowledge and autonomy to make decisions, remove barriers and drive the project forward.

Developing reporting and MI that provides progress against milestones, identified or potential risks etc., will support informed decision-making at the relevant forums and visibility of progress for Senior Management. Factoring in the likely impact of the December holiday period should also be a key consideration.

What comes next?

The next FCA milestone comes at the end of April 2023, when Manufacturers need to have completed all necessary reviews and changes to meet the four outcome rules for existing open products and services. This in turn will allow for distributors to be informed and take action to meet their own obligations ahead of the end of July 2023 implementation date.

The size and effort required to undertake this will vary by organisation, as well as the volume and complexity of products. It's therefore important that scoping has fully defined the extent of the firm's product book and the work required to undertake assessments within the time available. Similarly, a price and value approach will inevitably be dependent on the volume and complexity of the products or services offered.

It's essential that third parties are engaged at an early stage to establish a clear understanding of each party's responsibilities with regard to the activities they are undertaking to meet the new duty requirements. Dependencies should be agreed between parties and the requirement for these being achieved should be understood, or the risk and impacts if these are late or not met.

Whilst there is an extended timeline for closed products,  consideration should be given to the size and complexity of the firm’s back book to ensure that there is sufficient time to undertake any reviews necessary. Be careful not to underestimate the level of review activity that may be required at this stage, given the factors for consideration. For example, products or services that deliver differing standards of customer experience and outcomes will need to be considered and explained from a fairness perspective.

Scoping and analysis should help firms understand the level of activity demand across these portfolios and it may be a good time to ask questions such as:

• Are there opportunities to leverage the changes across open products for our closed books?
• How many customers have both open and closed products and could experience differing outcomes between now and 2023?
• What are the risks of delaying delivery action on the closed book in the short term?

Next steps

Strong leadership is needed to drive forward the end-to-end, top-to-bottom changes intended by the FCA. Consumer Champions should feel galvanised by the board review of implementation plans to create visibility of the delivery programme and the cultural shift it’s trying to achieve.

It's important to ensure sufficient consultation is taking place internally to really understand the extent to which changes need to be made and who or what is needed to make that happen.

As well as refining plans and dependencies, it’s time to start considering the requests and risks to raise to steering forums and the next board update; what are the key messages to deliver, and what are the key decisions required?