PS22/9 Consumer Duty
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ieDigital: The Barriers of Embracing PS22/9

It would be difficult to find a financial services firm that purposely intends to harm their consumers, but with the Consumer Duty deadline now a little over six months away, serious concerns remain around the success of the industry-wide adoption of the regulation.

The Financial Conduct Authority‘s (FCA) recently published January review of the regulation brought to light a high level of unpreparedness among financial service firms in adopting PS22/9 and the wider Consumer Duty. 

PS22/9 Consumer Duty
Jerry Young, CEO, ieDigital

Now in a timely response to those findings, Jerry Young, CEO of ieDigital, the portfolio company of Parabellum Investments, addresses the industry’s inattentiveness to this matter, and questions the type of barriers acting against the regulation’s widespread adoption. 

Ovum named ieDigital as a ‘market challenger for a digital banking platform’ during Young’s CEO tenure, and the Forrester wave recognised it as one of the world’s ‘most significant providers’ in the digital banking engagement platform space. Its current clients include Lloyds Bank, Santander, Toyota, Dudley Building Society and Cambridge and Counties Bank.

Young analyses the red flags raised in the FCA’s latest review and discusses ways to overcome identified barriers to adoption in this op-ed for The Fintech Times:

The barriers of embracing PS22/9

The current financial cost-of-living crisis is causing untold damage to the financial affairs of many people. Indeed, on a seemingly daily basis, we are being told that due to high inflation, soaring energy bills, fluctuating mortgage rates and food prices constantly seeming to spiral upwards, people are struggling to put money aside into savings.

As a result, never before has it been so important to encourage consumers to take control of their financial affairs, and to ensure they are receiving the very best in terms of customer service and service standards. This is a sentiment that is shared by financial regulators, who have recently stepped-up efforts to ensure financial services providers are giving the high level of service their customers expect.

Step forward PS22/9

The Financial Conduct Authority’s (FCA) website states that PS22/9 is designed as ‘a new consumer duty that will set higher and clearer standards of consumer protection across financial services and require firms to put their customers’ needs first’. It affects every type of firm covered by the FCA’s principles of business, ranging from traditional financial services providers such as banks and investment firms to the recently regulated group of PIs, EMIs and RAISPs.

The overarching principle is to deliver better consumer outcomes by following three rules: act in good faith, avoid causing foreseeable harm and support customers to achieve their financial objectives. Efforts should span the whole environment by applying these rules to products and services, price and value, consumer understanding and consumer support.

A barrier to implementation?

At first sight, it would appear that the ability of financial services providers to adhere to these rules is relatively straightforward. In the current turbulent economic climate, I do believe most financial services providers genuinely want to help their customers. After all, retaining current customers is always much more cost-effective than attracting new ones, and with the current cost-of-living crisis continuing to bite, most providers are being as flexible as possible and are positioning themselves as wanting to help.

However, there appears to be a major stumbling block in PS22/9’s roadmap, a problem which will result in many providers – through no fault of their own – failing to meet the compliance deadline.

A survey reveals that less than one in four FCA-regulated firms report that their current services are compliant. While the FCA has shifted the first implementation deadline for firms back from April 2023 to July 2023, there is a real risk that many will fail to meet this new deadline, especially as most do not have a solid plan in place for achieving compliance.

While each organisation will experience different challenges over the next few months, there are some common issues to look out for – and these issues are largely out of the direct control of financial services providers themselves.

Cultural shift

The FCA highlights the first major challenge in its guidance for PS22/9 and states that many firms will likely face a significant shift in culture and behaviour.

When you are a large financial services provider – or even a much smaller one – such changes do not open overnight. Often a substantial bedding-in process is needed before systems are even ready to go live, and for many organisations, the deadline for meeting the new standards is looming too closely on the horizon for them to meet.

A lack of the required capabilities

Particularly in large institutions, there’s often a complex infrastructure of data silos, point solutions, and disconnected teams to contend with.

Though many financial services providers consider themselves digitally enabled, commonly used core banking-focused tech solutions will not always cut it for experience-focused requirements.

A lack of clarity

Understanding is also proving to be a barrier for some organisations.

Around 10 per cent say they don’t have a complete understanding of what the duty expects of them, so it’s difficult for them to prepare effectively. The FCA is running events in the coming year to help educate teams on the rules and the best approach to achieving compliance.

Not making the most of the available data

Many firms aren’t making the best use of the data they have, especially when it comes to defining and servicing the ‘average customer’. The duty has a more specific focus on the needs of individual customers, especially when it comes to any potential indicators of vulnerability, this is when data and personalisation tools will come into their own.


Working towards PS22/9 compliance will be a big challenge for many organisations.

However, the outcome will be a desirable challenge. It is a solid opportunity for leaders to take advantage of the external pressure and accelerate key improvements to the customer experience, core systems, and collaboration processes.

In a competitive world where consumers demand more from their financial service providers, embracing this challenge is crucial.


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