Category: Compliance & AML · Reviewed by Jake Leat, Associate Director · Last reviewed June 2026
The allocation of Consumer Duty duties across the chain from manufacturer to end-customer — recognising that all firms in the chain have responsibilities for the parts they control or influence, with information flowing in both directions.
Distribution chain responsibilities is the FCA framework for allocating Consumer Duty obligations across the firms involved in designing, distributing and servicing a product. The principle is that each firm in the chain has duties for the part of the chain it controls or materially influences, and that information must flow effectively between manufacturer and distributor (and on through multi-tier distributors) so that each firm can meet its obligations.
FCA Handbook, PRIN 2A.3.16R, PRIN 2A.4.21R, PRIN 2A.7. Made under FSMA section 137A. Aligned with ICOBS 6A POG rules implementing UK retained IDD Article 25 (POG) and Commission Delegated Regulation (EU) 2017/2358.
The manufacturer designs the product, identifies the target market, conducts the fair value assessment and provides distributor information. The distributor reviews the manufacturer’s information, assesses how the product is distributed (channel, customer base, additional services and charges), confirms the target market alignment, and provides feedback to the manufacturer on observed outcomes. Where there are multiple distributors in a chain (e.g. MGA → broker → ancillary insurance intermediary), each tier has duties for its part. The framework requires effective information flow — manufacturers cannot just push information out, and distributors cannot just receive it without engagement.
Co-manufacturers (e.g. broker MGA + insurer carrier) share manufacturing duties on a basis they agree contractually but with full regulatory accountability for each on the relevant aspects. A pure distributor (Apex’s typical position) has the distributor duties — not the manufacturer’s. Where a distributor adds materially to a product (e.g. by bundling services), it may become a co-manufacturer under PROD 4 / ICOBS 6A.
Apex receives manufacturer fair-value statements and target market information from each carrier. Apex confirms the target market for its own distribution, monitors outcomes (claims experience, complaint patterns, retention, vulnerability indicators), and feeds back issues to the manufacturer. Where a manufacturer’s assessment appears materially inconsistent with observed outcomes, Apex escalates and (if unresolved) considers product withdrawal.
FCA Handbook, PRIN 2A.3.16R, PRIN 2A.4.21R, PRIN 2A.7, and ICOBS 6A. FCA Policy Statement PS22/9. UK retained IDD (Directive (EU) 2016/97), Article 25. UK retained Commission Delegated Regulation (EU) 2017/2358 (POG for insurance products).
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.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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