FCA Consumer Duty Focus Areas

The Financial Conduct Authority has published its Consumer Duty focus areas for 2025/26 as well as a programme for action intended to simplify regulatory requirements for firms in respect of the Duty.

The priorities identified by the FCA include embedding the Consumer Duty, providing support for firms, and pursuing sector-specific priorities. In assessing whether to give an initiative priority, the FCA considered factors including the need to address actual or potential harm, opportunities to streamline rules and reduce burden on businesses, and opportunities to improve outcomes for consumers.

Firms will need to be aware of these areas of focus and engage with the FCA where appropriate to ensure the Consumer Duty is properly embedded. 

Embedding the Duty

Four projects will be undertaken by the FCA in 2025/26 which look at how the Duty is being embedded across sectors. These projects comprise reviews of: 

• the products and services outcome;
• approaches to outcome monitoring; 
• customer journey design; and 
• the consumer understanding outcome. 

Supporting firms

For firms to be able to deliver good outcomes under the price and value outcome when conducting fair value assessments, the FCA has highlighted the need for several further studies, including in respect of pure protection insurance markets, unit-linked pensions and long-term savings, and premium finance markets. These studies look at consumer engagement with the respective products, transparency of charges across the value chain, and competitive constraints in the markets. 

Interim findings for the premium finance market study were published in July 2025 and findings in respect of the other studies are expected toward the end of the year.

Sector-Specific priorities

There are several areas of existing concern for the FCA in sectors where the FCA considers there is actual or potential harm. These include retail banking, consumer finance, and consumer investments. To address these concerns, the FCA is engaging with firms and industry on various programmes of work, for example by reviewing complex exchange-traded products, fair value in SME business current accounts, and peer-to-peer loan-based crowdfunding. 

We have extensive experience of advising boards, executives and senior managers on the Consumer Duty, including embedding the outcomes and building customer outcome indicators (including board reporting), so please get in touch with the team.