Consumer Duty, which came into force in July 2023, changed the baseline expectations the FCA places on wealth management firms. The headline requirements are well understood: clear pricing, suitable products, fair outcomes. Less well understood is what Consumer Duty implies for firms whose clients are approaching generational transitions — and for the heirs who will inherit those relationships.
The Consumer Duty logic, applied to heirs
Consumer Duty rests on four outcomes: products and services, price and value, consumer understanding, and consumer support. Each of those outcomes becomes materially more complex at the moment of wealth transfer. The heir is new to the relationship. They may not have chosen the advisor, the firm, or the product mix. They have not participated in the suitability conversations that shaped the portfolio. In most cases, the firm has never even met them.
The firm's Consumer Duty obligations transfer with the wealth. The firm's relationship with the person those obligations protect typically does not.
This creates an obligation gap. The firm inherits an obligation to provide fair value and clear understanding to someone it has never built a relationship with. If the heir later brings a complaint — on product suitability, on the clarity of the fee structure, on the quality of ongoing support — the firm's defence is not that it did its best with limited time. It is that it had years to build the relationship and chose not to.
What most firms are missing
The firms we have spoken to have a consistent blind spot. They think of Consumer Duty as a compliance requirement tied to the primary client. They treat heir engagement as a separate, softer initiative — relationship-building, not compliance. This framing is increasingly hard to defend.
A firm that systematically engages heirs — introduces them to the platform, educates them on the portfolio structure, documents their stated preferences — is building a Consumer Duty audit trail by default. A firm that does not is gambling that heirs will never exercise the rights Consumer Duty grants them. That gamble looks worse every year.
The compliance argument for heir engagement
We think the next decade of wealth management compliance will look significantly different from the last. Consumer Duty is just the first regime to name the heir as a stakeholder. It will not be the last. The firms that build systematic heir engagement — with proper documentation, audit trails, and stated preference tracking — will find themselves aligned with where regulation is heading. The firms that do not will be exposed.
- Document heir touch points with the same rigour as primary client meetings.
- Track heir-stated preferences and revisit them annually.
- Produce Consumer Duty audit trails that include the heir relationship, not just the primary account.
- Treat heir engagement as an obligation to deliver fair value over the lifecycle of the household, not an optional extra.
Heritance exists, in part, to make this easy. Our Consumer Duty audit trail is built into the advisor platform by default. Every heir interaction is logged. Every preference change is timestamped. Every family briefing is documented. Firms that use Heritance produce compliance-ready audit trails without additional workload — which, increasingly, is what the FCA expects.
