Category: Compliance & AML · Reviewed by Mark Fox, Broker · Renewals · Last reviewed June 2026
The FCA’s higher-standard conduct framework, introduced from 31 July 2023, requiring firms to act to deliver good outcomes for retail customers through cross-cutting rules and four outcomes covering products & services, price & value, consumer understanding and consumer support.
PRIN 2A is the FCA Handbook chapter that implements the Consumer Duty. The Duty sits at Principle 12 of PRIN and is detailed in PRIN 2A. It applies to firms that determine or have a material influence over retail customer outcomes throughout the distribution chain, requires firms to act in good faith, avoid foreseeable harm, enable customers to pursue financial objectives, and achieve four outcomes.
FCA Handbook, PRIN 2A. Introduced by Policy Statement PS22/9 with implementation on 31 July 2023 for new and existing products open to sale or renewal, and 31 July 2024 for closed products. Made under FSMA sections 137A, 137R, 138.
The Duty operates on three levels: (1) Principle 12 — the high-level standard requiring firms to act to deliver good outcomes for retail customers; (2) the three cross-cutting rules — act in good faith, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives; (3) the four outcomes — products and services, price and value, consumer understanding, and consumer support. Each firm in the distribution chain has duties for the part they control or influence, with manufacturers and distributors having distinct obligations.
For pure protection and general insurance products, the Duty operates alongside ICOBS 2, ICOBS 5 and ICOBS 6. The fair value test under PRIN 2A.4 is a specific requirement that operationalises the price and value outcome. The annual board report under PRIN 2A.8 is the principal evidence of governance.
Apex assesses its distribution chains, manufacturers’ fair value statements, target market alignment and customer outcomes data at least annually. The board approves a Consumer Duty annual report. Communications are reviewed against the consumer understanding outcome — including ICOBS 6 IPIDs, renewal letters, claims communications and digital journeys.
FCA Handbook, PRIN 2A. Financial Services and Markets Act 2000, sections 137A, 137R, 138. FCA Policy Statement PS22/9 (A new Consumer Duty). FCA Finalised Guidance FG22/5 (Consumer Duty implementation guidance).
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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