It applies to FCA-regulated firms (including insurance brokers and lenders), not to e-commerce generally. For customer-facing communications, including AI voice calls. The Duty expects them to be fair, clear, not misleading, and to evidence good outcomes, with extra care for vulnerable customers.
In a regulated voice-agent deployment, that means the AI opens with disclosure, captures the evidence the Duty expects, and routes vulnerable customers to a human quickly. The audit trail of every call supports the firm's Consumer Duty record-keeping.
Consumer Duty also shapes the line between a friendly payment reminder and hard debt collection: the FCA's CONC rules require forbearance and due consideration for customers in arrears, which is why early, brand-voice reminders sit in a very different regulatory space from late-stage collections.