Consumer Duty in 2026: The FCA Is Watching. Is Your Firm Ready?

If you're running an FCA-regulated firm with a small team, let me ask you something uncomfortable: if your supervisor knocked on the door tomorrow and asked to see your Consumer Duty framework — your assessments, your board report, your evidence trail — how long would it take you to pull it together?

If the answer is anything more than five minutes, you have a problem. And if you're still relying on spreadsheets and Word documents scattered across shared drives, you're not alone — but you are exposed.

The Consumer Duty isn't a box-ticking exercise that ended in July 2023. It's a living, breathing regulatory framework that the FCA has placed at the centre of its supervisory strategy through to 2030. And right now, in 2026, the regulator is turning up the heat.

Why Consumer Duty Is the FCA's Number One Priority

The Consumer Duty, built around PRIN 2A, fundamentally changed what the FCA expects from regulated firms. It moved the goalposts from "don't treat customers unfairly" to "prove that you're actively delivering good outcomes."

In their published strategy for 2025–2030, the FCA confirmed that the Consumer Duty remains a top priority. The FCA has also committed to conducting multi-firm thematic reviews across four critical areas: how firms design products and services, how they monitor outcomes, how they design customer journeys, and how their communications help consumers make informed decisions.

The Four Outcomes: The Backbone of Consumer Duty

Outcome 1 — Products & Services (PRIN 2A.3): Products and services must be designed to meet the needs, characteristics, and objectives of a target market.

Outcome 2 — Price & Value (PRIN 2A.4): The price consumers pay must be reasonable relative to the benefits they receive.

Outcome 3 — Consumer Understanding (PRIN 2A.5): Communications must be clear, fair, and not misleading.

Outcome 4 — Consumer Support (PRIN 2A.6): Firms must provide support that meets customers' needs throughout the product lifecycle.

The Cross-Cutting Rules

Act in good faith — honest, fair dealing that goes beyond the minimum.

Avoid causing foreseeable harm — actively identifying where your products or processes could cause harm.

Enable and support customers to pursue their financial objectives — proactively helping customers make decisions in their interests.

The Board Report: Your Most Important Document

Under PRIN 2A.8, firms must produce an annual board report setting out the results of their Consumer Duty monitoring. The FCA reviewed 180 firms' board reports and found many lacked sufficient data quality, board challenge was often performative, and action plans frequently lacked timescales and named owners.

What This Means for Your Firm

Fenchurch One is built for exactly this. Its Consumer Duty attestations, mapped to PRIN 2A, record what you've done against each requirement and why — and, like every attestation in the suite, they teach as they record.

The register suite and dashboard hold the evidence behind the four outcomes. Ready-made registers — complaints, conflicts, breaches and more — are dated, owned and evidenced, while the dashboard tracks your management information at a glance: on track, needs attention, or overdue.

When the annual board report is due, Fenchurch One drafts it for you. The one-page Executive Summary — or, on Growth and above, the full AI Compliance Report — draws only on your own records: nothing invented, nothing generic.

Everything the FCA expects to see behind the numbers is already there — your complaints, your MI, your attestations. Export it as a dated FCA proof pack, or share it with your supervisor through a revocable read-only Live Link.