Consumer Duty is almost here. Years in the making, and with the deadline now looming, there are plenty of firms that will see these next few weeks as the last big push to get ready.

So the big question, it would seem, is how many will succeed? How many, on 31st July, will be able to honestly say that there is nothing they more could possibly do to support each vulnerable customer they serve?

The honest answer, I expect, is not many.

Of course, there will be firms that simply aren’t prepared. Those that haven’t taken the guidance seriously and urgently need to improve. But even the best will fall somewhere short. There will be few – if any – in a position to genuinely support their vulnerable customers as Consumer Duty might ultimately like.

At first glance, this might seem a bleak prediction. But if we interrogate it, we’ll see that it doesn’t need to be. The trap many firms are falling into is viewing the 31st July as the end of this initiative. They believe that if they can put the required measures in place now, they’ll be able to tick customer vulnerability off their do-do lists and move on.

In reality, the end of July isn’t a finish line. Instead, it should be seen as the referee’s kick-off whistle, marking the beginning of a deeper understanding of vulnerability and of how to ensure good outcomes.

Just like many of the firms rushing to put Consumer Duty plans in place, we should remember that the FCA is also new to monitoring vulnerability outcomes. And while those who do nothing will certainly face repercussions, Consumer Duty has not been devised as a means of punishing firms that fall short. What the FCA wants is for vulnerability to be taken seriously, in a way that one could argue it previously hasn’t. It wants to see that the foundations are in place, ready for us to build on as we develop our understanding.

This idea of development is crucial. The entire point of Consumer Duty is that supporting vulnerable customers is something we’ll work on and improve at over time. So what the FCA will be looking for on 31st July isn’t necessarily that every single base has been undeniably covered. What it really wants is to see that we’re all in the game.

If Consumer Duty is really about continuous improvement, then our long-term goal should be to look at the measures currently put in place and question how we can go a step further.

For some, providing staff with vulnerability training might seem like the most logical way forward. But while training is certainly important, it isn’t everything. What’s actually required is a recurring process of implement, test, refine and learn. We need to assess the data gathered so far and analyse it for ways we can improve going forward.

The best way to begin this process is by looking at your own data. Even with purely internal data, you’ll be able to see what’s missing and refine. However, those who are most successful in their development will also have an external view. So many firms are new to this process of collecting vulnerability data. If there are thousands trying to solve the same problem, and to make the same improvements, it makes a huge amount of sense to look at other firms – even other industries – and try to benefit from their learnings.

While some might have been looking forward to putting Consumer Duty behind them this summer, the topic of vulnerability is here to stay. As we develop our understanding, the outcomes we deliver for vulnerable customers will start to gradually improve. But we shouldn’t expect an overnight transformation. We’ll be in escalation for years.

For those looking to make the most of the data available – whether it’s their own or from across the industry – a third-party specialist with a technology-driven assessment tool can help to accelerate the process, removing bias and subjectivity from the process, and ensuring consistency across a whole client base. By combining clinical expertise with hard data, they’re able to reassure firms that their systems and controls are affecting the change the regulator is looking for.

In the long run, this process will benefit everyone; clients and firms alike. If you’re struggling, or if you know that you need to bring in additional expertise, don’t delay.