Two years into Consumer Duty, and here's where we are: 82% of mortgage brokers are optimistic about their prospects, yet 42% reckon the regulation hasn't changed how they operate.
That's quite the spread.
Either a significant portion of the industry has cracked the code so well that compliance feels effortless, or there's a sizeable group who haven't fully grasped what's coming. Given that July 2025 brought unlimited fining powers (with example penalties reaching £2.34 million), it's probably worth examining which camp you're in.
Consumer Duty isn't just asking brokers to be good at their jobs. It's asking them to prove it. With data. Systematically. To regulators who now have serious teeth.
The problem? The infrastructure to actually do that doesn't really exist yet.
What Consumer Duty Actually Demands
Strip away the FCA's regulatory language and Consumer Duty boils down to three questions:
- Are you delivering fair value for your fee?
- Can you demonstrate positive customer outcomes?
- Do you have the evidence to prove both?
For brokers charging an average £500 fee, that's a reasonable ask. Except here's the rub: what does "positive outcome" actually mean in mortgage broking, and how do you measure it systematically?
Completion rate? Time to complete? Client satisfaction? Rate secured versus market average? The ability to navigate complex cases that would have been declined elsewhere?
Most brokers would argue it's all of the above, weighted differently depending on client circumstances. Try putting that into a quarterly MI report that satisfies the FCA.
The Evidence Gap
Despite broker market share climbing to 41% (beating bank-direct channels at 30%), the industry still struggles with robust management information systems. This isn't necessarily a competence issue. It's an infrastructure problem.
You can track your own performance. You can survey your clients. You can maintain detailed case notes. But when a prospective client is researching mortgage brokers, they're seeing price comparison sites, anonymous reviews, and marketing promises. Your actual track record? Invisible.
This creates an awkward situation. Consumer Duty demands transparency and evidenced outcomes, yet provides no mechanism for brokers to showcase these to the people who need to see them most: prospective clients making a selection decision.
The FCA wants better outcomes. The market can't easily identify who's delivering them.
The Technology Problem
Here's a stat that should worry the industry: 60% of brokers are positive about AI's potential, yet 41% report that mortgage processing times are the same or slower than two years ago.
Technology enthusiasm hasn't translated into operational improvement. The average UK buyer still waits 87 days between mortgage offer and completion. In London, that stretches to 94 days.
Meanwhile, 31% of brokers are calling for greater technology integration, which is code for "we've got multiple systems that don't talk to each other and it's making our lives harder, not easier."
The tools exist. The integration doesn't. And whilst everyone's debating which AI platform to adopt, the fundamental question remains unanswered: how do you systematically demonstrate that working with you delivers better outcomes than going direct to a bank?
What Success Actually Looks Like
The brokers who are genuinely thriving under Consumer Duty aren't the ones who've simply added a compliance officer and called it done. They're the ones who've reframed the regulation as a competitive advantage.
They're implementing proper MI systems, not because the FCA demands it, but because it tells them which parts of their service are working and which aren't. They're collecting systematic client feedback at multiple touchpoints. They're tracking completion rates, processing times, and outcome quality metrics.
But they're also honest about the limitation: this is all internal data. Valuable for operations and compliance, but invisible to prospects.
The Market Shift Coming
With £330 billion in mortgage expirations throughout 2025 and first-time buyer numbers up 19% to 341,068 in 2024, the opportunities are significant. Interest rates have dropped from 5.25% to 4% with three cuts this year, and 78% of brokers expect residential applications to increase over the next six months.
Market conditions are favourable. But the selection criteria for brokers are changing.
Clients (particularly younger, digitally native first-time buyers) expect to see verified track records. They've grown up with Uber ratings, Airbnb reviews, and Amazon seller metrics. The idea that choosing a financial professional involves less transparency than booking a taxi seems increasingly absurd to them.
This generational shift intersects with Consumer Duty's evidence requirements to create something new: a market that rewards provable excellence over marketing promises.
Building the Missing Infrastructure
This is where platforms like TRUVERI enter the picture. Not as another technology add-on, but as the missing infrastructure layer that connects Consumer Duty's requirements with client selection behaviour.
Transaction-verified professional reputations (completion rates, verified client feedback, specialist expertise proven through track record) give brokers a way to demonstrate outcomes externally, not just internally. Consumer Duty compliance shifts from defensive documentation to proactive reputation building.
It's the difference between having excellent performance metrics locked in your internal systems and having independently verified track records visible to the clients who are trying to decide whether to work with you.
The Honest Assessment
If you're in the 42% who reckon Consumer Duty hasn't changed your practice, it's worth asking whether that's because you've always operated to these standards, or because you haven't yet built the evidence systems the regulation demands.
If you're confident in your outcomes but struggling to demonstrate them systematically, you're not alone. The industry infrastructure hasn't caught up with regulatory expectations.
And if you're wondering whether transparency really matters when you've got a strong referral network and word-of-mouth reputation, consider this: 341,068 first-time buyers entered the market last year. Most of them started their search online. What did they see when they searched for you?
The winners over the next few years won't be the brokers with the lowest fees or the flashiest websites. They'll be the ones who made their excellence provable. Consumer Duty isn't just changing compliance requirements. It's changing how professional reputation works in the mortgage market.
The question is whether you're building for that future or hoping it won't arrive.