With the passing of the 31 July 2024 deadline for the first Consumer Duty annual report, the FCA will continue to scrutinise insurers and intermediaries to ensure that they are delivering good consumer outcomes as mandated by the Consumer Duty. Key to this is being able to monitor for and evidence good outcomes, rather than relying on an absence of evidence of poor outcomes. With the FCA noting that it continues to see “substandard service levels across insurance sectors", we expect the FCA to continue to keep a close eye on insurers and intermediaries and their compliance with the Consumer Duty. The FCA has also flagged significant concerns about failings on the part of both insurers and intermediaries with their product oversight and governance obligations, finding many examples where firms appear not to be meeting regulatory requirements. We expect to see several insurers and intermediaries being required to appoint skilled persons under s166 of the Financial Services and Markets Act, to assess their product oversight and governance frameworks and identify possible harms that may have resulted from non-compliance.