Consumer Duty · Educational hub

Consumer Duty (PRIN 2A) for UK regulated professional firms

Reviewed by Matthew Bartlett, Director, Apex Insurance Brokers Limited · Published 14 July 2026

The FCA Consumer Duty (PRIN 2A) came into force July 2023 for new products and July 2024 for closed books. It applies to FCA-regulated firms serving retail customers. This hub explains the framework, how it interacts with existing SRA / ICAEW / ARB conduct rules, and its implications for PI cover.

The four outcomes

1. Products and services

Products must be designed to meet the needs of the identified target market. Distribution must reach that market. No harm through inappropriate distribution.

2. Price and value

Products must offer fair value. Value assessment must be documented and demonstrable.

3. Consumer understanding

Communications must be clear, fair and not misleading. Consumers must be able to make informed decisions.

4. Consumer support

Support must enable consumers to pursue their financial objectives. No sludge; no barriers to switching, cancelling, complaining.

The cross-cutting rules

Act in good faith toward retail customers.
Avoid causing foreseeable harm.
Enable and support retail customers to pursue their financial objectives.

Which professions are directly affected

FCA-regulated firms

Insurance brokers, IFAs, mortgage advisers, consumer credit firms — direct application. Consumer Duty is the primary conduct framework.

SRA-regulated solicitors

Where serving retail (consumer) clients, Consumer Duty principles apply in parallel with SRA conduct rules. The SRA has published joint guidance.

ICAEW / ACCA-regulated accountants

Where serving consumer clients (personal tax, some estate work), Consumer Duty principles apply.

ARB-regulated architects

Consumer clients (residential extensions, self-build) trigger Consumer Duty application through the ARB Code interaction.

Vulnerable customer treatment (FG21/1)

FCA Finalised Guidance 21/1 sets standards for identifying and supporting vulnerable customers. The four drivers of vulnerability: health, life events, resilience, capability.

Identification — recognise indicators.
Record — maintain firm-level record where appropriate.
Adjust — modify service, communication, and process where needed.
Escalate — internal escalation for complex cases.

PI implications

Consumer Duty creates new claim triggers:

Fair-value breach — consumer alleges the product wasn't fair value.
Consumer-understanding failure — consumer alleges they didn't understand the product.
Consumer-support failure — sludge or barrier claim.
Vulnerable-customer treatment failure — failure to identify or accommodate vulnerability.

PI cover should specifically address Consumer Duty defence-cost coverage. Wording review at renewal essential.

Documentation and audit

Consumer Duty compliance is documentation-heavy. Firms must maintain:

Board-level accountability — Consumer Duty Champion role, annual board report.
Value assessment records — periodic review evidence.
Communication testing — evidence that materials are understandable to target market.
Vulnerable customer records.
Complaint records reflecting Consumer Duty categorisation.

Frequently asked

What is the FCA Consumer Duty?

PRIN 2A, in force from July 2023 for new products, July 2024 for closed books. Requires FCA firms to act in good faith, avoid causing foreseeable harm, and enable customers to pursue financial objectives.

Does Consumer Duty apply to solicitors?

Not directly, unless the firm is FCA-authorised for regulated activity. But Consumer Duty principles inform SRA parallel-conduct standards where serving retail clients.

Does Consumer Duty apply to insurance brokers?

Yes, directly. FCA-authorised insurance intermediaries fall within scope. Retail-consumer treatment is subject to the full Consumer Duty framework.

What's the vulnerable customer angle?

FCA Finalised Guidance 21/1 requires identification, recording, adjustment and escalation for vulnerable customers. Four drivers: health, life events, resilience, capability.

What are the PI implications?

New claim triggers around fair value, consumer understanding, consumer support, and vulnerable customer treatment. PI wording should specifically cover Consumer Duty defence costs.

What's the enforcement risk?

FCA supervisory attention through the Consumer Duty implementation programme. Enforcement action published on FCA warning-list and Final Notices.