Category: Compliance & AML · Reviewed by Chrissie Anderson, Client Executive · Last reviewed June 2026
The three behavioural standards at the heart of the Consumer Duty — acting in good faith, avoiding foreseeable harm, and enabling customers to pursue their financial objectives — that apply to every part of the consumer-facing distribution chain.
The cross-cutting rules are the three operational standards through which the Consumer Duty is delivered. They apply to all in-scope retail business and across all four outcomes. They require firms to (a) act in good faith towards retail customers; (b) avoid causing foreseeable harm to retail customers; and (c) enable and support retail customers to pursue their financial objectives.
FCA Handbook, PRIN 2A.2 (cross-cutting rules). Introduced by FCA Policy Statement PS22/9. Operative from 31 July 2023 for new and existing products open to sale or renewal, and from 31 July 2024 for closed products.
“Acting in good faith” is the standard of honest, fair and open dealing, consistent with the reasonable expectations of customers. “Avoiding foreseeable harm” requires the firm to consider what harm could reasonably be foreseen and to take steps to prevent it. “Enabling and supporting” requires the firm not just to refrain from harming customers but actively to help them pursue their objectives — including through clear communications, accessible support, and reasonable accommodation.
The cross-cutting rules apply across the four outcomes but their practical bite varies by activity. For product design (manufacturer activity), the avoid-harm rule drives the target market and value assessment. For customer service (distributor activity), the enable-pursue rule drives the resourcing of support channels and complaint handling.
A complex commercial policy aimed at SMEs (within retail customer scope for many SMEs as “consumers” under DISP terms) sold without explanation of key exclusions could engage the “avoid foreseeable harm” rule. A renewal process that imposes friction on customers seeking to switch insurers could engage the “enable and support” rule.
FCA Handbook, PRIN 2A.2. FCA Policy Statement PS22/9. FCA Finalised Guidance FG22/5.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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