TCF — definition for UK financial services

TCF (Treating Customers Fairly)

Treating Customers Fairly (TCF) is the FCA's long-standing initiative requiring regulated firms to embed fair treatment of customers throughout their business, built around six consumer outcomes. It is rooted in Principle 6 of the Principles for Businesses and has, for retail customers, largely been superseded and raised by the Consumer Duty.

Treating Customers Fairly (TCF) is the FCA’s long-running framework for embedding the fair treatment of customers into firms’ culture, strategy and day-to-day operations. Introduced in the mid-2000s, it gives practical shape to Principle 6 of the Principles for Businesses, which requires firms to pay due regard to customers’ interests and treat them fairly. TCF is built around six measurable consumer outcomes spanning the entire product lifecycle, from design through to post-sale service.

The six TCF outcomes

The framework asks firms to evidence six outcomes: a culture in which fair treatment is central; products and services designed for identified target markets; clear and timely information for consumers; suitable advice; products that perform as consumers were led to expect; and the absence of unreasonable barriers to switching, claiming or complaining after the sale. Firms were expected to gather management information demonstrating these outcomes were being delivered, not merely to have policies on paper.

Relationship to the Consumer Duty

For retail customers, the Consumer Duty (in force from 31 July 2023 under the new Principle 12 and the PRIN 2A rules) has raised the bar above TCF. Where TCF required firms to treat customers fairly, the Consumer Duty requires them to act to deliver good outcomes, supported by the four outcomes of products and services, price and value, consumer understanding and consumer support. The Consumer Duty disapplies Principles 6 and 7 in its retail scope, so TCF now principally governs business that falls outside the Duty.

Why it still matters

TCF remains relevant for firms with business outside the Consumer Duty’s retail scope, and its outcomes-based thinking laid the groundwork for the Duty. Compliance teams must understand both regimes and which applies to each part of the business.

Consumer Duty, conduct risk and COBS.

Frequently asked questions

What are the six TCF consumer outcomes?

The FCA's six Treating Customers Fairly outcomes are: (1) consumers can be confident fair treatment is central to the firm's culture; (2) products and services are designed to meet identified consumer needs and targeted accordingly; (3) consumers are given clear information and kept appropriately informed; (4) advice is suitable to the customer's circumstances; (5) products perform as firms led consumers to expect; and (6) consumers face no unreasonable post-sale barriers to changing product, switching provider, claiming or complaining.

What is the relationship between TCF and Principle 6?

TCF gives practical effect to Principle 6 of the FCA's Principles for Businesses, which requires a firm to 'pay due regard to the interests of its customers and treat them fairly'. The six TCF outcomes were the FCA's framework for measuring whether firms were delivering on Principle 6 across the product lifecycle.

Has the Consumer Duty replaced Treating Customers Fairly?

For retail customers, the Consumer Duty (in force from 31 July 2023 under Principle 12 and the PRIN 2A rules) sets a higher standard than TCF, requiring firms to act to deliver good outcomes rather than merely treat customers fairly. The Consumer Duty disapplies Principles 6 and 7 where it applies. TCF and Principle 6 continue to be relevant for business outside the Consumer Duty's retail scope.