Consumer Duty requirements review: update

We set out below how we’re streamlining our rules and reducing complexity for businesses following the introduction of the Consumer Duty.

We update this page regularly. It was last updated in June 2026 to set out progress on our Duty requirements work.

Following the Consumer Duty (the Duty) requirements review Call for Input, we set out progress on the action we have taken so far, and further action we will take following stakeholder input.

Our action plan at the end of this page includes:

A summary of the work we have completed since March 2025.
The work that we continue to progress.
New work that has been announced as a result of the Leeds reforms[2].
The new work that we are committing to as part of this Consumer Duty streamlining exercise and review.

Our priorities for streamlining our regulatory requirements

In March 2025, we set out steps we will take to simplify our requirements of firms in a Feedback Statement (PDF)[3], responding to comments on our July 2024 Call for Input (PDF)[4]. As part of our strategy’s (PDF)[5] priority to support growth, we are focused on areas where streamlining could achieve:

More flexibility: Enabling firms to innovate and take advantage of technology, and to tailor approaches to customers' circumstances, particularly those with characteristics of vulnerability.
More predictability: Providing more clarity on our priorities and upcoming consultations, helping firms plan.
Improved efficiency: Reducing the time, cost and complexity involved in meeting our expectations, while ensuring good customer outcomes.

We hosted a Regulatory Summit in July 2025, attended by over 90 representatives from across the financial services sector, government bodies and consumer groups to discuss the proposals in our Feedback Statement, and to determine what else, if anything, we could do. Participants were supportive of the actions and plans we set out and provided additional feedback, which we've set out below.

At the request of the Chancellor, we have also worked with wholesale firms and trade bodies representing them to understand their concerns about the application of the Duty. Much of this feedback echoes issues raised at the Summit. At the request of the Chancellor, we have also worked with wholesale firms and trade bodies representing them to understand their concerns about the application of the Duty. Much of this feedback echoes issues raised at the Summit. The tables below set out our progress towards delivering on our 4-point plan (PDF)[6] to address this feedback and give wholesale firms greater confidence to apply the Duty proportionately.

Our wider work on the Duty

Our work to streamline our requirements is a key component of our approach to implementing the Duty. For more on our wider programme of work on the Duty, see our latest workplan[7].

Next steps

Stakeholders will have opportunities to feed into our work as it progresses.

We will also continue to look for opportunities to streamline our requirements of firms. We continue to provide ways for stakeholders to raise concerns about overly complex or overlapping requirements to inform our future priorities, including through the FCA and Practitioner Panel survey.

We will run a series of sector-level roundtables over the course of 2026 and continue to provide updates on feedback received and future priorities. We will also provide an update on the cumulative benefits of this work in due course.

Feedback on our requirements of firms

We received feedback on our requirements via our 2025 Regulatory Summit, key themes of which we've responded to below. These included:

Clarifying how the Duty applies to firms in distribution chains.

Our response

We have heard the challenges firms face in interpreting our requirements as they apply to different roles across distribution chains. We have:

Set out our final rules (PDF)[8] for co-manufacturing in insurance, streamlining our requirements by allowing some firms to appoint a single ‘lead’ firm under PROD 4.2.
Issued an interim notice (PDF)[9] to clarify our supervisory approach and expectations where firms work together to manufacture products.
Consulted on changes to the scope and proportionality of the Consumer Duty[10]. We are consulting on a targeted package of reforms which will remove business with non-UK consumers from the Duty's scope, make it clearer where the Duty applies and where it does not, clarify when and how firms can rely on each other when they work together in distribution chains, and explain the interaction between the Duty and other product governance rules.

Providing clearer guidance on the scope of rules, including the Duty.

Our response

We remain committed to continuing to share our views on good and poor practice and areas for improvement. See our workplan[7] for progress, as well as a wider range of publications and resources[11].

In our consultation on the scope and proportionality of the Duty, we also set out proposals to amend the scope of the Duty, to ensure the right firms are applying our expectations.

Alongside this wider work, our insurance proposals include changes to simplify and clarify conduct requirements for insurance firms, covering distribution chains, international business and disclosure. Together, these proposals are intended to reduce complexity while maintaining consumer protections.

Ensuring we coordinate effectively with the Financial Ombudsman Service.

Our response

We understand the need to ensure alignment between the Financial Ombudsman and the FCA on the interpretation of FCA rules and have worked closely with the government and the Financial Ombudsman on a significant set of proposals to modernise the redress system.

For more detail and further updates, see our consultation page[12].

Improving consistency in rules and definitions.

Our response

We are improving the consistency in our definitions and updating our core rules to reflect changes over time.

We have:

Consulted on updates to our client categorisation rules[13] in our Conduct of Business Sourcebook. We aim to publish a Policy Statement later this year.
Published final rules (PDF)[8] to simplify rules for insurance firms, intermediaries and funeral plan providers, which included simplifying SME thresholds. We issued a Handbook Notice (PDF)[14] which includes final rules to streamline and simplify certain PPI, packaged bank account and product governance requirements, and the removal of the 12-month product review requirement for funeral plan products.
We will also review the rest of our core definitions (eg retail customer) to promote consistency and clarity and will share more on our proposals through 2026.

Updating legacy disclosure rules.

Our response

The Duty, and changes in markets and technology, give us an opportunity to look again at the best ways of supporting consumer understanding. We agree with the desire to simplify disclosure rules and ensure that our rules are consistent and future-proof so that they can support consumers. We have:

Published final rules on Consumer Composite Investments[15] disclosure requirements to give product manufacturers and distributors more freedom and flexibility in product design and disclosure summaries. The transition period began in April 2026, with the new regime coming fully into force by June 2027.
Sought views on Annual Percentage Rate and cost disclosure as part of our financial promotions consultation[16]. We plan to update further later in 2026.
Following the Call for Input (PDF)[4], we reviewed targeted suggestions for amendments to disclosure rules in BCOBS. We determined the firm burden resulting from targeted disclosure changes alone would not correspond with improved outcomes for consumers or firms. We have therefore concluded this work.

We are also exploring opportunities to conduct further cross-cutting work on disclosures to ensure a consistent approach is adopted across our Handbook where appropriate.

There is a clear consensus on the need to deliver the above at pace, and we remain committed to doing so.

At this time, we have decided not to proceed with broader reviews of our product governance, client asset and training and competence sourcebooks. We will, however, keep this under review through the ongoing review mechanisms described above.

Feedback on our regulatory approach

Through the Summit and this review, we have heard feedback about our wider regulatory approach, on topics including our authorisations' timelines, how we consult and implement policy, navigability of our Handbook, and our approach to risk and growth.

A broad package of measures has been announced through the Leeds Reforms, covering our authorisations timelines, the senior manager regime, the redress system, and our support for firms as they scale up and grow. We are currently taking this work forwards together with the other areas of work to support growth as set out in our letter to the Prime Minister in January 2025 (PDF)[17]. We also provided an update on our progress (PDF)[18] in December last year.

Our action plan

In FS25/2, we committed to several workstreams which would simplify our requirements of firms. We have already delivered some of these commitments and are actively progressing others throughout 2026, as well as a wider programme of reform and simplification work.

Complete

See commitments and progress made

Commitment	Progress
Improving accessibility of our rule review feedback tool.	Rule review feedback tool, which allows users to directly feedback where they think our rules could be improved, has been embedded into the new Handbook website[19], which went live on 5 September 2025.
Withdraw historic supervisory communications.	Over 90 historic Dear CEO and Portfolio letters were retired in April 2025[20]. Over 100 multi-firm and thematic reports were retired in August 2025[21].
Simplifying the insurance rules.	We published final rules[22] in December 2025 to give more flexibility and responsibility to insurance firms and funeral plan providers. Separately, our simplification of certain insurance rules, such as those related to PPI and packaged bank accounts can be found in our Handbook Notice (PDF)[16].
Review Assessment of Value reporting for asset management.	We published final rules (PDF)[23] in October 2025 to streamline the Assessment of Value (AoV) reporting requirements for authorised fund managers (AFMs). AFMs now need to report only the conclusion of the AoV assessment, rather than detailed findings.
Smaller firm guides	After seeking views on our proposed approach, content and structure in CP25/37 (PDF)[24], we published our pilot regulatory guide for credit brokers[25] in May 2026.
Targeted clarification of Handbook Materials.	Following our consultation in CP25/37 (PDF),[28] where we committed to updating specific areas of outdated rules and guidance identified through our Call for Input, we have implemented a package of technical amendments to simplify and streamline our Handbook. This includes changes to our investment and borrowing powers rules (PDF)[26], as well as simplification of certain insurance and funeral plan rules, removal of references to Principles 6 and 7 and Treating Customers Fairly, and targeted clarifications to our CASS rules in our Handbook Notice (PDF)[26]. We explained in CP25/37 (7.13) that we were considering whether it would be beneficial to update our guidance for firms on the fair treatment of vulnerable customers in FG21/1[26]. We do not currently have any immediate plans to update the guidance, although we are still considering whether this would be beneficial and will provide a further update if we decide to do so.

In progress

See commitments and progress made

Commitment	Progress
Review the international application of our insurance conduct rules.	We sought input in our May 2025 CP25/12: Simplifying the insurance rules[25] on how we might disapply elements of our conduct rules for international business. We have consulted on this further in CP26/22[34] alongside further simplification proposals, and have also consulted on disapplying the Duty in respect of business with non-UK customers in CP26/23[10].
Mortgage rule review.	You can find further details of our mortgage rule review,[26] where we set out our current progress including across our roadmap (PDF)[27].

Commitment

Progress

Review the international application of our insurance conduct rules.

We sought input in our May 2025 CP25/12: Simplifying the insurance rules[25] on how we might disapply elements of our conduct rules for international business.

We have consulted on this further in CP26/22[34] alongside further simplification proposals, and have also consulted on disapplying the Duty in respect of business with non-UK customers in CP26/23[10].

Mortgage rule review.

You can find further details of our mortgage rule review,[26] where we set out our current progress including across our roadmap (PDF)[27].

Our future priorities

Reviewing the foundations Future-proofing disclosure Reducing the administrative burden Streamlining requirements

Reviewing the foundations

Date	Workstream	Commitment	Deliverable
Q4 2025	Simplifying Insurance Rules[35] (complete).	Existing commitment	Policy statement
	Review of client categorisation and conflict of interest rules[14] (complete).	Mansion House commitment	Consultation paper
	Supporting consumers' pensions and investment decisions: rules for targeted support [26](complete).	Wider policy work	Policy statement (please see below for simplifying the pensions and investment advice rules consultation)
Q1 2026	Modernising the redress system[13] (complete).	Wider policy work	Joint consultation paper with the Financial Ombudsman.
Q1 2026	Simplifying the pensions and investment advice rules[27] (complete).	Wider policy work	Consultation paper
Q2 2026	Review the application of the Duty to non-UK customers[36] (complete).	New commitment	Consultation paper
	Targeted support[41] (complete)	Wider policy work	Targeted support regime goes live.
	Review of the Senior Managers & Certification Regime[27] (complete).	Wider policy work	Most changes took effect from 24 April 2026. Please find further details in the link.
Q3/Q4 2026	Review of the Senior Managers and Certification Regime	Wider policy work	Consultation paper for phase 2.
Q4 2026	Review the application of the Duty to non-UK customers[44].	New commitment	Policy statement
	Simplifying the pensions and investment advice rules.	Wider policy work	Policy statement
	Review of the client categorisation and conflict of interest rules.	Mansion House commitment	Policy statement
H2 2026	Modernising the redress system.	Modernising the redress system.	Further updates are planned by the Financial Ombudsman later this year.
2026	Review our core definitions	New commitment	Update to share more on our proposals.

Future-proofing disclosure

Date	Workstream	Commitment	Deliverable
Q4 2025	Consumer Composite Investments[17] (complete).	Wider policy work	Policy statement
Q1 2026	Review advertising consumer credit rules, including discussion on whether to review the rules on the disclosure of Annual Percentage Rates (APRs)[18] (complete).	Existing commitment	Consultation paper
Q2 2026	Reviewing TCFD product-level disclosure requirements[26] (complete).	Ongoing policy work	Consultation paper
Q4 2026	Reviewing TCFD product-level disclosure requirements.	Ongoing policy work	Policy statement
H2 2026	Review advertising consumer credit rules.[49]	Existing commitment	Policy statement

Reducing the administrative burden

Date	Workstream	Commitment	Deliverable
Q4 2025	Reviewing Assessment of Value reporting for asset managers (PDF)[27] (complete).	Existing commitment
	Interim notice on our supervisory approach to co-manufacturing[9].(complete).	Mansion House commitment	Supervisory statement
	Complaints reporting review (complete)[26].	Wider policy work	Policy statement
Q1 2026	Reviewing insurance premium pricing returns (PDF)[27] - update to the market (complete).	New commitment	Market study
Q2 2026	Changes to rules and guidance relating to distribution chains[47] (complete).	Mansion House commitment	Consultation paper
Q1 2027	Changes to rules and guidance relating to distribution chains.	Mansion House commitment	Policy statement

Streamlining requirements

Date	Workstream	Commitment	Deliverable
Q4 2025	Targeted clarifications of Handbook materials[25] (complete).	Existing commitment	Consultation paper
Q4 2025	Smaller firm guides[57] (complete).	Existing commitment	Discussion chapter in 'tidying up' consultation paper.
Q1 2026	Smaller firm guides[29] (complete).	Existing commitment	Pilot in consumer finance sector.
Q2 2026	Targeted clarifications of Handbook materials (PDF)[32] (complete).	Existing commitment	Handbook Notice and Policy Statement: COLL changes (PDF)[31] Simplification of certain insurance and funeral plan rules, removal of references to Principles 6 and 7 and Treating Customers Fairly, and targeted clarifications of our CASS rules
Q3 2026	Reform of FCA remuneration codes for solo-regulated firms.	Wider policy work	Consultation paper
H2 2026	Expanding consumer access to investments.	Wider policy work	Feedback statement

30/07/2026 : Information changed Small updates under completed work, date updated for upcoming work, and duplicate sentence removed.

29/06/2026 : Information changed Updates across the page to reflect current work.

09/12/2025 : Link added Links added to Q4 2025 publications

05/12/2025 : System update No content change

24/10/2025 : Information changed Correction to priorities under 'reviewing foundations'

01/10/2025 : Information changed Review advertising consumer credit rules PS updated to H2 2026

First published: 29/09/2025 Last updated: 30/07/2026 See all updates

Consumer Duty requirements review: update

Our priorities for streamlining our regulatory requirements

Our wider work on the Duty

Next steps

Feedback on our requirements of firms

Clarifying how the Duty applies to firms in distribution chains.

Our response

Providing clearer guidance on the scope of rules, including the Duty.

Our response

Ensuring we coordinate effectively with the Financial Ombudsman Service.

Our response

Improving consistency in rules and definitions.

Our response

Updating legacy disclosure rules.

Our response

Feedback on our regulatory approach

Our action plan

Complete

See commitments and progress made

In progress

See commitments and progress made

Our future priorities

Reviewing the foundations

Future-proofing disclosure

Reducing the administrative burden

Streamlining requirements

On this page

More on the Duty