The following update is information published by the Financial Conduct Authority (FCA).
Our priorities for 2025 to 2026, including embedding the Duty, support for firms and sector-specific focus areas
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7 May 2026: We’ve updated this page to include new priorities, links to work that has now been published, and further details on existing priorities where they may have changed.
Under our strategy for 2025 to 2030, the Consumer Duty (the Duty) remains a priority for our work to deepen trust, rebalance risk, support growth and improve lives.
We are relying on the Duty as much as possible rather than creating new prescriptive rules. So embedding the Duty well across sectors is critical as it will help ensure that consumers are supported and will help avoid the need for future prescriptive regulation.
We remain committed to sharing examples of good and poor practice, so that sectors can learn, and publishing the findings of our work. Below, we’ve set out our priorities for 2025/26.
Alongside these priority areas, we’ve also published an ambitious programme of action to simplify our requirements following the introduction of the Duty, to give more flexibility, predictability and improved efficiency for firms.
For updates on wider regulatory initiatives and our work, see the Regulatory Initiatives Grid, and our annual work programme.
Priority areas for 2025/26
Our Duty focus areas cover thematic, multi-firm and market-wide work, relevant to a wide set of stakeholders.
We’ve not included firm-specific supervisory work nor the everyday supervisory work on the Duty. For example, understanding how firms are delivering good outcomes through the products and services they offer, including looking at any issues around closed products and services.
We’ve given a short description of the work and expected timelines. These may both change if we need to prioritise new and emerging consumer harms for specific sectors or the industry.
We’ve prioritised initiatives where:
- We can share more information on good and poor practice and our expectations to help industry deliver better outcomes.
- We see the greatest need to address actual or potential harm.
- We need more data to understand how firms are embedding the Duty and delivering good consumer outcomes.
- There are opportunities to streamline our rules, reduce burden on businesses and improve outcomes for consumers.
Embedding the Consumer Duty and sharing good practice
To understand how firms are improving consumer outcomes, we intend to carry out a handful of multi-firm projects to look at how the Duty is being embedded across sectors.
We may ask for data, but only when we need it. And we’ll offer feedback where firms need help with implementation.
We recognise different firms face different challenges. We want firms to take an approach that is proportionate to their size and to the activities they undertake. Where appropriate, we’ll set out different approaches smaller firms could take.
In 2025/26, we have 4 cross-cutting projects:
- Review of products and services outcome – How firms are designing products and services to meet customer needs, including those with characteristics of vulnerability.
- Review of firms’ approaches to outcomes monitoring – How firms are responding to our outcomes monitoring requirements.
- Review of firms’ customer journey design – Looking at the design and delivery of firms’ customer journeys to ensure customers’ needs are met, with a particular focus on how firms apply friction at key points in the journey.
- Review of the consumer understanding outcome – How firms’ communications are helping consumers make informed decisions. This review has now been published.
The Duty, vulnerability and data protection
Through joint engagement with the Information Commissioner’s Office (ICO), we have heard that some firms can struggle to balance how to meet their vulnerability, data sharing, and data protection expectations.
Together with the ICO, we have published a joint statement on our expectations.
Supporting firms to deliver good outcomes under the price and value outcome
We know firms have come across challenges when conducting fair value assessments and have questions about our expectations.
We want firms to use robust analysis to offer fair value, and to identify and take action where they are not.
Our priorities include:
- Market study into pure protection insurance – Exploring consumers’ engagement with, and understanding of, the pure protection products they are buying, the competitive constraints on insurers and intermediaries, and firms’ incentives, behaviour and practices. We have published our interim report and will be consulting further with stakeholders ahead of the final report, which we intend to publish in Q3 2026.
- Unit-linked pensions and long-term savings – Looking at transparency of charges across the value chain and how firms assess overall product value. We intend to publish findings in H1 2026.
- Market study into premium finance– Reviewing whether people who borrow to pay for motor and home insurance are receiving fair, competitive deals. We have published our findings, and we will continue to monitor prices in the premium finance market. Where firms are not providing a fair deal, we will act. This may include challenging individual firms and, in the most significant cases, enforcement action.
Sector-specific priorities
We’ve planned work to tackle areas of existing concern in sectors where there may be harm, or the potential for harm.
Firms should also expect a general focus on their implementation and embedding of the Consumer Duty and customer outcomes as part of any supervisory engagement.
Retail banking
- Fair value in SME business current accounts – How firms providing small business current accounts are complying with the price and value, and consumer understanding outcomes. We have communicated our findings directly to firms, following our review. We have also shared findings with other firms providing small business current accounts who were not involved in the project.
Consumer finance
- Consumer understanding in the credit card market – How consumers understand the terms and conditions of credit card products and if they get enough clear information to support decision making, in particular, when looking to take out a promotional offer. We have communicated our findings directly to firms involved in the review.
- Reviewing the financial promotion rules for consumer credit – We’re consulting on proposals to simplify our financial promotions rules and remove duplication where the Consumer Duty already sets clear expectations for how firms should support consumer understanding. We also opened a discussion on ways to improve how cost of credit information is presented to consumers.
Insurance
- As part of our response to the Which? super-complaint into home and travel insurance, we are extending our work to look at how home and travel insurance firms are meeting the Consumer Understanding outcome of the Duty.
Consumer investments
Firm and industry engagement continues, including through our Raising Standards Together regional events, focusing on:
- Tackling poor identification of clients with characteristics of vulnerability by wealth managers.
- Expectations for wealth and advice firms when assessing fair value.
- Risks to providing unsuitable advice.
We’ll also work on:
- Complex exchange traded products (Complex ETPs) – Following our review of trading apps, we have assessed whether firms are meeting Consumer Duty expectations for retail customers investing in complex ETPs – a small proportion of the wider ETP market. We have published our findings.
- Loan-based crowdfunders (peer-to-peer) – We have reviewed firms’ outcomes statements to ensure consumers have a clear understanding of whether peer-to-peer platforms achieve the returns they advertise. We have given specific feedback to firms in our review, and we have asked for views on whether further regulatory interventions are needed in the peer-to-peer lending market.
Wholesale buyside
- Model portfolio services – We’re looking at how model portfolio services (MPS) firms are implementing the Consumer Duty. We expect to publish findings in autumn 2026.
Sustainable finance
- Sustainability disclosure requirements (SDR) and investment labels – We’ve paused work to finalise rules on extending SDR to portfolio management.
Source: FCA
