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.

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.
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, attended by over 90 representatives from across the financial services sector, government bodies and consumer groups to discuss the proposals in our March 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. We have written to the Chancellor[6] to outline how we will address feedback.

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 will continue to provide mechanisms for stakeholders to raise concerns about overly complex or overlapping requirements. For example, we will explore including questions on Handbook simplification in the next survey of the Practitioner Panel.

We will run a series of sector-level roundtables over the course of 2026, and will provide a further update on our next steps in 2026. 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 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 will:

Take forward the proposals on co-manufacturing in insurance in our consultation to simplify insurance rules (PDF)[8] – setting out next steps before the end of 2025.
Provide more clarity on our supervisory approach and expectations where firms work together to manufacture products in Q4 2025.
Consult in H1 2026 on changes to rules on the application and requirements of the Duty, including through distribution chains. We will make it clearer where the Duty applies and where it doesn’t. We will assess whether our existing exemptions are working well and whether they go far enough, eg for business-to-business activities.
We will also consult on removing business with non-UK customers from the scope of the Duty.

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

Our response

We remain committed to continue to share our views on good practice and poor practice, which we will continue publishing in 2026 covering products and services, outcomes monitoring, and consumer understanding.

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 Treasury and the Financial Ombudsman on a significant set of proposals to modernise the redress system.

These proposals, which are being consulted on jointly with the Financial Ombudsman and government, would introduce changes to the legislative test by which the Financial Ombudsman determines cases, and introduce formal referral mechanisms to improve co-ordination and consistency.

This is a strong package of measures which we believe will address the concerns raised. We will share more on our next steps in H1 2026.

Improving consistency in rules and definitions.

Our response

We see opportunities to improve the consistency in definitions and for us to update some of our core rules to reflect changes over time.

We will:

Consult on updates to our client categorisation rules in our Conduct of Business Sourcebook in Q4 2025.
Take forward the proposals to align SME definitions in our consultation (PDF)[8] to simplify insurance rules – setting out next steps before the end of 2025.
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 will:

Complete the reform to retail disclosures as part of our Consumer Composite Investments work by Q4 2025.
Seek views on APR and cost disclosure as part of our CONC 3 consultation paper planned in early 2026.
Consult on updates to our retail banking disclosure rules in 2026.

We will also explore 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.

We will also deliver focused work this year on our Systems and Controls requirements relating to the management of conflicts of interests and will be taking forward reforms to the senior manager regime (with associated rationalisation of systems and controls requirements).

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 committed to 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)[9].

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. We will deliver the remaining commitments later this year and in early 2026.

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[10], which went live on 5 September.
Withdraw historic supervisory communications.	Over 90 historic Dear CEO and Portfolio letters retired in April. Over 100 multi-firm and thematic reports retired in August[11].

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[12] on how we might disapply elements of our conduct rules for international business. We will consult on disapplying the Duty in respect of business with non-UK customers in mid-2026.
Mortgage rule review.	Following a consultation paper in May 2025, we issued PS25/11: Mortgage Rule Review: First steps to simplify our rules and increase flexibility[13] in July 2025, simplifying specific responsible lending and advice rules for mortgages. We sought further views on the future of the UK mortgage market in DP25/2: Mortgage Rule Review: the future of the mortgage market[14], in June 2025. We are analysing responses and will announce further details in due course.
Review Assessment of Value reporting for asset management.	In our June 2025 Quarterly Consultation Paper[15], we proposed changing requirements for asset managers to report annually on the value they provide to investors. We will issue a Policy Statement in Q4 2025.
Simplifying the rules for insurance and funeral plans.	We consulted, in our May 2025 CP25/12: Simplifying the insurance rules, on proposals allowing firms greater flexibility over How often they review value under product governance rules. Co-manufacturing arrangements, and Changes to which rules apply to commercial insurance. We will issue a Policy Statement in Q4 2025.
Review advertising consumer credit rules.	We will review the financial promotions rules, with a particular focus on CONC 3.5, to identify opportunities to reduce the level of prescription currently required and to be more outcomes-focused, in line with the consumer understanding outcome of the Duty. We will consult in Q1 2026.
Consultation with targeted clarifications of Handbook materials.	We committed to consulting on updating specific areas of outdated rules and guidance highlighted in feedback to the Call for Input, including outdated references and updates to some of our client asset rules. See below for more information*. We will consult in Q4 2025.
Guides for smaller firms.	We committed to piloting a guide to help support smaller firms with outcomes-focussed regulation, so firms could see all of our requirements in one place. The pilot is planned for consumer finance firms in Q1 2026. We will seek views on our approach in our Q4 2025 targeted clarification consultation.

*Consultation with targeted clarifications of Handbook materials - planned changes

Technical changes to COLL 5 – streamlining and simplifying our investment and borrowing powers rules in Chapter 5 of the Collective Investment Schemes sourcebook.
Changes to CASS rules relating to:
- Amending record-keeping requirements for certain due diligence relationships.
- Broadening reconciliation rules, to allow the use of records from sources that were not envisaged when the rules were introduced and to allow less frequent receipts.
- Adding flexibility to rules on removal of interest owed to firms.
Addressing outdated references, including to principles 6/7 and retiring Treating Consumers Fairly guidance.
Simplifying insurance rules - Proposals to remove product-specific rules, in ICOBS, those relating to PPI, packaged bank accounts and GAP insurance, which were discussed, but not consulted on in the Simplifying Insurance Rules CP[13].
A discussion chapter inviting views on the pilot of small firms guides, as committed to in our March Feedback Statement (PDF)[3].

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.	Existing commitment	Policy statement
	Review of client categorisation rules.	Mansion House commitment	Consultation paper
	Advice Guidance Boundary Review.	Wider policy work	Policy statement
Q1 2026	Modernising the Redress Framework.	Wider policy work	Joint policy statement with the Financial Ombudsman and further consultation planned.
Q2 2026	Review the application of the Duty to non-UK customers.	New commitment	Consultation paper
	Advice Guidance Boundary Review.	Wider policy work	Regime goes live.
	Review of the Senior Managers & Certification Regime.	Wider policy work	Implementation date of new regime.
Q4 2026	Review the application of the Duty to non-UK customers.	New commitment	Policy statement
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.	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).	Existing commitment	Consultation paper
H2 2026	Review advertising consumer credit rules.	Existing commitment	Policy statement
2026	Reviewing retail banking disclosures.	New commitment

Reducing the administrative burden

Date	Workstream	Commitment	Deliverable
Q4 2025	Reviewing Assessment of Value reporting for asset managers.	Existing commitment
Q4 2025	Interim notice on our supervisory approach to co-manufacturing, including its relationship to the distribution chain.	Mansion House commitment	Supervisory statement
Q1 2026	Currently reviewing insurance premium pricing returns and will update the market before the next reporting window in Q1 2026.	New commitment
Q2 2026	Changes to rules and guidance relating to distribution chains.	Mansion House commitment	Consultation paper
Q4 2026	Changes to rules and guidance relating to distribution chains.	Mansion House commitment	Policy statement

Streamlining requirements

Date	Workstream	Commitment	Deliverable
Q4 2025	'Tidying up' consultation paper – to consult on targeted clarifications of our Handbook materials.	Existing commitment	Consultation paper
Q4 2025	Smaller firm guides.	Existing commitment	Discussion chapter in 'tidying up' consultation paper.
Q1 2026	Smaller firm guides.	Existing commitment	Pilot in consumer finance sector.

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: 30/09/2025 Last updated: 05/12/2025 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

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More on the Duty