On 10 July 2026, the FCA updated its price and value guidance for the first time since September 2024. The update adds fresh examples of what’s working and what isn’t across firms, drawn from supervisory work spanning retail banking, consumer finance, wealth management and pensions, asset management, payments and crypto assets.
One finding is worth pulling out on its own. The treatment of long-standing customers compared with new ones is still an area the regulator wants firms to keep working on.
For pricing and risk teams, this might look like a familiar compliance issue. But what the FCA expects firms to evidence depends heavily on the data behind it. Can you reliably identify which customers are still on legacy terms, and show whether they’re receiving fair value?
Key takeaways
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The concern itself is familiar. In its cash savings work, the FCA found firms offering higher rates to new customers while existing customers with similar balances remained on lower-paying, off-sale accounts.
The issue was whether firms could show those customers were still receiving fair value. In some cases, firms also hadn’t considered whether customers on lower rates were less likely to switch or renegotiate, leaving long-standing customers at greater risk of receiving poor value.
This follows an earlier review of the Consumer Duty’s first full year, where the treatment of long-standing customers compared with new ones was already identified as an area requiring further work. The same review highlighted support for vulnerable customers and cancellation processes.
The fact that long-standing customers have appeared again in the FCA’s latest guidance suggests firms should expect continued scrutiny of how these customers are treated and how those outcomes are evidenced.
Further reading: We looked at the FCA’s wider findings in Three years of the Consumer Duty: the honest scorecard.
The July update doesn’t confine its examples to savings. It draws on findings across seven sectors, and the FCA is clear that firms should consider how the underlying principles apply to their own products and services, even where an example comes from another market.
So if you’re in consumer credit, wealth management or pensions, the cash savings findings are still relevant. How are long-standing customers faring against those on current products? And if there is a difference, what evidence is behind it?
The update also gives firms more to measure their own approach against. An example from another sector may expose something that hasn’t yet come up in your own supervisory conversations.
PwC’s outlook for the year ahead is useful context here. It expects Consumer Duty scrutiny to intensify through 2026, with cross-sector reviews producing findings that have relevance beyond the firms directly involved.
For price and value teams, there’s good reason to keep an eye on what the FCA is finding elsewhere in financial services.
Pulling up a customer’s current product, balance, and price is the easy part. The harder work starts when you need to go backwards.
What terms has that customer been on over time? How long have they been there? What would an equivalent customer have received during the same period? And can you still answer those questions after a product migration, platform change or acquisition?
One of the FCA’s examples gives a good indication of what’s expected. A firm segmented customers by behaviour, then tracked deposit levels, withdrawals, and charges to understand whether particular groups were at risk of poor value. Other firms could see different outcomes between customer groups, but struggled to explain how those groups had been defined or how the segmentation reflected the way customers actually used the product.
For long-standing customers, firms need to be able to:
But the account history is only one part of what may have changed.
A long-standing customer may have been on the same product for years while their circumstances have changed considerably. Redundancy, a drop in income, illness or growing financial pressure can all change the position of someone who, on the account record alone, looks much the same as they did before.
Data On Demand’s Know Your Vulnerable Customer (KYVC) uses current vulnerability and change-of-circumstance data to show where a customer’s position may have shifted since that account history was created.
The records may exist, but they could span three legacy platforms, two migrations, or an acquired portfolio. Linking all of that back to today’s customer record isn’t always straightforward.
One industry analysis published in late 2025 found that 92% of UK financial services firms still rely on legacy infrastructure, with around 70% of IT budgets spent maintaining it.
There’s also the question of timing. The FCA says fair value assessments shouldn’t be created after the event to justify decisions already made. The analysis needs to have informed the decision at the time.
When a review lands, firms need to be able to reconstruct what happened, when it happened, and which customers were affected.
Price and value may have a defined owner, but the evidence behind it doesn’t tend to follow the same organisational boundary.
For long-standing customers, the assessment can depend on several layers of history lining up:
This is also where external consumer data can add another layer. Where older records contain outdated contact details or customer information has changed over time, additional identity and address data can help firms reconnect those records to the customer they hold today.
Each change to the portfolio creates another point where that continuity can weaken. A pricing history can be complete at source and still become difficult to use if the customer, product and account records around it no longer join reliably.
For price and value teams, that changes the scope of the work. Assessing long-standing customers can draw on data architecture, identity resolution and historic account records well beyond the pricing function itself.
With the FCA now asking firms to consider good and poor practice from across financial services, that capability is likely to be called on repeatedly across products and portfolios.
There are two situations worth testing against your own long-standing customer base:
You can see exactly where a customer is today. What’s harder to see is how they got there. For instance, how long have they been on those terms? What changed along the way? And what was happening with comparable products while they stayed where they were?
A current snapshot won’t give you that history. For long-standing customers, it can leave a sizeable part of the fair value assessment unanswered.
The pricing history is there. So is the current customer record. Connecting the two with confidence is where things can become difficult. A migration, account change or historic identifier can interrupt the trail, particularly in older parts of the back-book. If that history can’t be reliably connected to the customer held today, the evidence becomes harder to piece together.
This is one area where Data On Demand can add another source of customer information. FIN.TRACE can identify updated addresses, telephone numbers and email addresses where customer contact details have changed, while 4.ID provides additional identity data that can strengthen matching and verification.
Take a long-standing customer who has been through a product or platform change.
Could you trace their account and pricing history from the original record through to today without manually rebuilding it?
If the answer changes depending on the system they came from, when they migrated or whether someone can find an old identifier, you already know where to look.
Further reading: We looked at what happens when important customer information gets lost between firms in The FCA has closed the data protection excuse on vulnerability sharing.
Long-standing customers have now appeared more than once in the FCA’s price and value findings. If the next review landed tomorrow, how much of their history could you confidently put in front of the regulator?
Could you follow a customer through product and platform changes? Reconnect older records to the person you hold today? And do it quickly, across a large customer base?
Then there’s what’s happened to that customer since. Someone who has held the same product for five or ten years may have gone through changes in income, employment, health or financial circumstances that won’t necessarily show up in the account history you’re reviewing.
Know Your Vulnerable Customer (KYVC) helps fill in some of that more recent context, using current vulnerability and change-of-circumstance signals alongside the data firms already hold.
A Data On Demand Proof of Value can test a sample of your existing portfolio to identify what additional customer information and vulnerability signals are available.
If long-standing customer outcomes are on your Consumer Duty agenda, see how a Data On Demand Proof of Value works.
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