A Step-by-Step Guide to Consumer Duty Governance for Automotive Retailers

The Financial Conduct Authority’s Consumer Duty has reshaped expectations across the automotive retail sector. No longer is compliance simply about avoiding misconduct; it is about proactively delivering better customer outcomes, evidencing oversight, and embedding a culture of accountability.

For dealerships and dealer groups, building robust, repeatable Consumer Duty governance is now business-critical. It protects your customers, strengthens your brand, and supports sustainable commercial performance. But operationalising the Duty can feel complex without the right structure and tools.

This step-by-step guide outlines how automotive retailers can implement effective Consumer Duty governance — in a way that is scalable, efficient, and performance-focused.

What Is Consumer Duty Governance for Automotive Retailers?

Consumer Duty governance refers to the internal controls, processes, culture, and monitoring frameworks that ensure customers consistently receive fair value, clear information, and products that meet their needs.

In the automotive sector, this spans the full journey — from finance and insurance discussions to product presentation, affordability assessments, vulnerability identification, and aftersales support.

Effective governance must be:

• Structured (clear accountability and documented processes)

• Consistent (repeatable across locations and individuals)

• Evidence-Based (supported by audit trails and data)

Establish Clear Ownership and Accountability

Consumer Duty requires defined accountability throughout the organisation — not just at senior leader level.

Key actions:

• Appoint a Consumer Duty Champion within the leadership team.

• Allocate role-based responsibilities across sales, compliance, customer experience, and aftersales.

• Ensure frontline staff understand how their actions impact customer outcomes.

With ComplianceTrak, responsibilities and workflows can be mapped to roles, ensuring tasks, attestations, and training are consistently tracked and evidenced.

Understand Your Customer Segments and Their Needs

To deliver fair outcomes, retailers must genuinely understand customer demographics, financial circumstances, and levels of vulnerability.

Key actions:

• Build customer profiles and journey maps.

• Identify vulnerability triggers and support points.

• Embed suitability assessments into every discussion.

InsightTrak supports structured vulnerability identification and evidencing.

Strengthen Customer Communication and Transparency

Clarity is central to Consumer Duty. Customers must understand what they’re purchasing, why it’s recommended, and what it means for them today and long-term.

Key actions:

• Ensure all product explanations are clear, jargon-free, and purpose-led.

• Use digital tools to standardise the presentation of finance and insurance options.

• Provide a balanced discussion around benefits, limitations, and eligibility.

Our digital Customer Presentation Journey supports dealers in delivering consistent, fair, and compliant communication every time.

Monitor, Audit, and Evidence Customer Outcomes

Consumer Duty isn’t just about good intentions — it’s about evidence.

Retailers must be able to demonstrate that customers are:

• Receiving suitable products

• Getting fair value

• Supported throughout the decision-making process

• Not experiencing foreseeable harm

Key actions:

• Introduce regular sampling of sales transactions.

• Conduct document consistency checks across invoices, finance agreements, demands and needs statements, and order forms.

• Use automation to flag high-risk cases for manual review.

The upcoming ComplianceTrak Audit Module supports automated and manual auditing to highlight risks and drive corrective action.

Foster a Culture of Continuous Improvement

Consumer Duty is not a one-time exercise. It is an evolving framework that requires ongoing review.

Key actions:

• Use performance insights to guide training, coaching, and process improvements.

• Share outcomes and learning across locations and teams.

• Align commercial objectives with responsible customer value delivery.

The OnTrak Learning Platform provides targeted training modules, role-based development, and performance analytics aligned to regulatory requirements.

Building Consumer Duty Governance That Drives Performance

Strong Consumer Duty governance does more than ensure compliance — it strengthens trust, enhances customer experience, and supports long-term profitability.

With the right structure, culture, and technology, automotive retailers can create a compliance framework that:

✅ Reduces operational risk

✅ Ensures consistent and fair outcomes

✅ Enhances dealership reputation

✅ Supports ethical and sustainable sales growth

How ComplianceTrak Helps

ComplianceTrak provides a complete, automotive-specific governance ecosystem that supports:

• Customer journey compliance

• Vulnerable customer oversight

• Training and competence development

• Automated and manual auditing

• Centralised reporting to senior management and the FCA

If your organisation is ready to transform compliance into a competitive advantage, our team is ready to help.

Book a Demonstration

See how ComplianceTrak can simplify Consumer Duty governance for your business.

→ Contact our team to schedule a discovery session.