Bite-size: FCA updates Consumer Duty focus areas
On 24 September 2026, the Financial Conduct Authority updated its Consumer Duty focus areas page for 2025/26. The update adds links to work published since the page was last substantively revised on 7 May 2026, when new priorities were added.
The FCA confirms that the Consumer Duty remains a priority under its 2025 to 2030 strategy. It is relying on the Duty as much as possible rather than creating new prescriptive rules, and says that embedding the Duty well across sectors will help avoid the need for future prescriptive regulation. Alongside this, it is running a programme of action to simplify its requirements following the introduction of the Duty.
The page covers thematic, multi-firm and market-wide work. It does not cover firm-specific supervision or everyday supervisory work on the Duty. Firms should nevertheless expect Consumer Duty implementation and customer outcomes to feature in any supervisory engagement.
Why it matters
The 24 September change is largely housekeeping, but the page now reads as a scorecard of completed work. Three of the four cross-cutting reviews have been published: products and services, outcomes monitoring, and consumer understanding. The fourth, on customer journey design and the use of friction, remains in progress. The FCA has also published its work on price and value in pure protection insurance, unit-linked pensions and long-term savings, and premium finance.
With findings now public across most of the programme, supervisors have a clear benchmark against which to test individual firms.
For consumer-credit and motor-finance firms, two priorities stand out: consumer understanding in the credit-card market, and the review of the financial promotion rules for consumer credit. The consultation on that review, CP26/15, closed on 17 June 2026. It proposes removing provisions in CONC 3 that may be overly prescriptive or outdated, and relying instead on the Duty’s consumer understanding outcome. It also opened a discussion on cost disclosure: whether the Representative APR supports consumer understanding of the cost of credit, whether the mandatory representative example helps, and whether the 51% threshold for determining a Representative APR remains appropriate.
The FCA continues to treat fair value as an active supervisory and enforcement issue. In premium finance, including borrowing to pay for motor and home insurance, it will continue to monitor prices. Where firms are not providing a fair deal, it may challenge individual firms and, in the most significant cases, take enforcement action.
What firms need to know
The FCA’s cross-cutting programme for 2025/26 focuses on how firms are embedding the Duty across sectors:
● Products and services (published). Whether products and services are designed to meet customers’ needs, including those with characteristics of vulnerability.
● Outcomes monitoring (published). How firms are responding to the outcomes monitoring requirements.
● Consumer understanding (published). Whether firms’ communications help consumers make informed decisions.
● Customer journey design (in progress). The design and delivery of customer journeys, with a particular focus on how firms apply friction at key points.
The FCA wants firms to take a proportionate approach reflecting their size and activities and, where appropriate, will set out different approaches smaller firms could take. This does not remove the need to evidence that the firm has considered and monitored customer outcomes.
For consumer-finance firms, the credit-card work examines whether customers understand product terms and conditions and receive enough clear information to make decisions, particularly when taking out a promotional offer. The FCA has communicated its findings directly to the firms involved in the review.
For insurers, the FCA is extending its work, as part of its response to the Which? super-complaint into home and travel insurance, to look at how home and travel insurance firms are meeting the consumer understanding outcome.
The FCA and the ICO have published a joint statement on expectations where firms are balancing vulnerability, data sharing and data protection obligations. Firms should consider it alongside their processes for identifying, recording and responding to customers’ characteristics of vulnerability.
What firms should do now
Compliance officers should ensure that Consumer Duty governance and management information can evidence outcomes, not merely process completion.
Review the published findings from the three completed cross-cutting reviews and assess whether the good and poor practice identified is relevant to the firm’s products, communications, support channels and governance.
Re-test customer communications, especially promotional credit offers, cost disclosures, key exclusions, eligibility criteria and customer journey prompts. Evidence should show that communications support informed decision-making.
Review fair value assessment methodologies, including the quality of underlying data, treatment of foreseeable harm, escalation routes and remedial-action records.
For firms involved in insurance premium finance or related distribution chains, assess whether the firm can evidence that pricing and the overall proposition offer fair value.
For home and travel insurers, test communications against the consumer understanding outcome ahead of the FCA’s extended work.
Align vulnerability processes with the joint FCA and ICO statement, particularly where data-sharing concerns may have limited the firm’s ability to provide appropriate support.
Prepare for the CP26/15 policy statement. Map current CONC 3 controls and financial promotion approval processes against the proposals, particularly Representative APR and representative example disclosures, so the firm can respond promptly once final rules are published.
Key takeaways
Evidence outcomes. The FCA’s focus has shifted towards whether firms can show that customers receive good outcomes in practice.
Treat fair value as live supervision. Robust analysis and prompt remediation remain essential, particularly in premium finance and complex pricing models.
Revisit credit communications. Promotional offers and cost-of-credit disclosures should be clear, tested and supported by meaningful customer-understanding evidence.
Use published findings. Three of the four cross-cutting reviews are now published and provide a practical benchmark for governance, monitoring and communications.
Prepare for the CP26/15 policy statement. The consultation has closed. Proposed CONC 3 changes and the Representative APR discussion are not final rules, but firms should be ready to act when they are.
If you would like support in this area please get in touch with the Auxillias team via the details on this page.
