By Eilis Corcoran, Senior Compliance Consultant
The Financial Conduct Authority (FCA) is signalling a new phase of Consumer Duty: one focused on simplification and scope clarification. Dubbed Consumer Duty 2.0, the next phase is expected to unfold through 2026. While the core principles remain unchanged, the regulator is now focused on refining expectations and reducing unnecessary complexity. For wealth managers, platforms and retail-facing private equity (PE) products, this creates both opportunity and risk.
1. Simplification and scope: What has the FCA said?
The FCA has committed to:
- Clarifying expectations around co-manufacturing, distribution chains and client categorisation
- Consulting on exemptions for non-UK customers and certain distribution models
- Streamlining guidance by removing outdated communications and consolidating rules
These changes are designed to reduce regulatory friction while reinforcing the Duty’s core objective: delivering good outcomes for retail customers.
2. Product governance: reassessing roles and responsibilities
For wealth managers and platforms, clarification around co-manufacturing is critical. Firms must:
- Revisit product governance frameworks to clarify roles and accountabilities
- Review distribution agreements to confirm responsibilities for target market assessments, value assessments and customer communications
- Ensure product design and approval processes are proportionate and well-documented
Retail-facing PE products, often distributed via platforms, must ensure disclosures, risk warnings and liquidity features align with the needs and understanding of their target market.
3. Fair value: a renewed focus on evidence
Fair value remains a regulatory priority. Firms should:
- Reassess value assessments in light of any pricing changes or product enhancements since the Duty’s initial implementation
- Benchmark fees and charges against comparable products
- Document pricing rationale and review it regularly
For PE products, this includes clear disclosure of performance fees, exit costs and any dilution effects.
4. Management information: from compliance to insight
Management information (MI) remains central to demonstrating compliance. Under Consumer Duty 2.0, firms should:
- Enhance MI dashboards to include segmented data on customer outcomes, complaints and product usage
- Track outcomes for vulnerable customers and those with complex needs
- Use MI to inform product reviews, board discussions and risk assessments
Firms are increasingly using automation and advanced analytics to turn MI from a reporting obligation into a strategic tool. Platforms, in particular, must ensure they can access and interpret MI from third-party manufacturers and distributors.
5. Board oversight: embedding the Duty at the top
Boards must remain actively engaged in Consumer Duty oversight. This includes:
- Regular review of MI and fair value assessments
- Oversight of product governance and distribution arrangements
- Ensuring simplification doesn’t dilute the Duty’s core principles
Training and board reporting should evolve to reflect the FCA’s updated expectations and sector-specific guidance.
What firms should do now
With regulatory expectations evolving and 2026 shaping up to be a pivotal year for compliance risk, firms should:
- Conduct a gap analysis against updated FCA expectations
- Review and update product governance and distribution frameworks
- Strengthen MI and board reporting processes
- Prepare for increased scrutiny of fair value and customer outcomes
How we can help
We support wealth managers, platforms and PE firms prepare for and embed Consumer Duty 2.0 through:
- Product governance reviews and co-manufacturing assessments
- Fair value benchmarking and documentation
- MI dashboard design and board reporting support
- Distribution chain mapping and oversight frameworks
- Board and SMF training on evolving FCA expectations
To discuss how our compliance consulting team can support your firm’s Consumer Duty 2.0 readiness, contact us today.
