Thought leadership
"Anything done or omitted": Supreme Court judgment on the scope of a principal's liability for its appointed representative
14 April 2026
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Today, with 6 months to go before the Consumer Duty comes into force, the FCA has published a review of how firms are planning to implement the Duty.
The FCA reviewed a sample of implementation plans and found that many firms show they understand and embrace the shift to delivering good customer outcomes, which the Duty will bring, and have established extensive programmes of work to comply with it properly.
However, the FCA also found that some firms are further behind in their planning, so there is a risk that they may struggle to apply the Duty effectively once the rules come into force.
Over the next 6 months the FCA wants firms to particularly focus on:
'The Consumer Duty will bring about a step change in the way financial services firms treat their customers and we welcome the work firms are doing to implement it. Given the scale of the reform, we recognise that some firms need to make significant changes. For firms which are further behind in making the necessary changes, there is time to put that right and for them to show they are acting in the spirit of the new Duty.'
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