FCA

Financial Conduct Authority (UK)

Medium Impact

FCA highlights Consumer Duty product design, monitoring and distribution findings

Published

Jul 7, 2026

Topics

Consumer Duty, Product governance, Target market, Consumer outcomes, Third-party distribution, Vulnerable customers

Executive Summary

The FCA has published a business-facing blog setting out findings from its review of how firms design, monitor and distribute products and services under the Consumer Duty. The publication does not create new Handbook rules, deadlines or regulatory templates, but it is an important supervisory signal. The FCA says many firms are improving product governance, use of management information and ownership of outcomes after sale, including where third parties distribute products. However, it also identifies inconsistent practice, including overly broad target markets, weak links between monitoring data and corrective action, and limited visibility of distributor activity. Firms in scope of the Consumer Duty should treat the publication as a prompt to benchmark product approval, review, fair value, outcomes monitoring and distributor oversight controls against FCA examples of stronger and weaker practice. The main implementation impact is likely to be evidential: firms should be able to show how customer needs, characteristics and behaviours inform product design and how monitoring leads to timely improvements.

What Changed

newFCA publishes cross-firm product design findings

Firms already had Consumer Duty obligations, including requirements to act to deliver good outcomes for retail customers.

New

The FCA has provided additional supervisory insight into how it expects firms to evidence effective product design, review and distribution oversight.

modifiedTarget market evidence expectation sharpened

Some firms used broad or generic target markets, making suitability and outcome assessment harder.

New

Firms are expected to be able to explain who the product is for, what those consumers need, and how product features, price and service delivery meet those needs.

modifiedMonitoring must link to action

Monitoring existed in some firms but did not always demonstrate how insight was escalated or used to improve outcomes.

New

Good practice is to use monitoring information to identify emerging risks and take action before avoidable consumer harm crystallises.

modifiedDistribution chain oversight remains a focus

Some firms had limited visibility after products were distributed through third parties.

New

Firms should maintain sufficient oversight of distribution arrangements to identify poor outcomes that may otherwise go unnoticed.

newNo new reporting template or filing requirement

Consumer Duty implementation and closed-product deadlines were already set through earlier FCA policy and guidance.

New

No new implementation date, reporting deadline or regulatory form is introduced by this publication.

Business Impact

Who is affected

Directly affected

FCA-authorised firms manufacturing or distributing retail financial products and services subject to the Consumer Duty.

Indirectly affected

appointed representatives, intermediaries, outsourced service providers, product distributors, compliance advisers, internal audit teams and customer operations functions supporting in-scope retail products.

Jurisdictions

United Kingdom

Business processes

Product approval and product review, Target market definition and customer segmentation, Fair value assessment and pricing governance, Consumer outcomes monitoring and MI escalation, Distributor and third-party oversight, Vulnerable customer and customer support controls

Estimated effort

Medium

Compliance risk

Medium

Affected Reports

Consumer Duty product approval and review packTarget market assessment and customer needs analysisFair value assessment fileConsumer outcomes monitoring MI dashboardDistributor oversight and information-sharing control record

Field	Validation rule

Recommended Actions

7 suggested next steps· derived from source analysis

1
AI generatedStep 1 of 7
Benchmark in-scope product governance frameworks against the FCA’s review findings, documenting where current practice aligns or where remediation is needed.
2
AI generatedStep 2 of 7
Review whether target market definitions are sufficiently granular and supported by evidence of customer needs, characteristics, behaviours and vulnerability considerations.
3
AI generatedStep 3 of 7
Test whether complaints, feedback, usage, cancellation and servicing MI are linked to clear escalation routes, governance challenge and corrective product or journey changes.
4
AI generatedStep 4 of 7
Assess distributor oversight arrangements, including whether expectations, information flows and testing provide adequate visibility of consumer outcomes after sale.
5
AI generatedStep 5 of 7
Update Consumer Duty board or committee reporting to distinguish data collection from demonstrable action taken to improve outcomes.
6
AI generatedStep 6 of 7
Use internal audit, compliance monitoring or second-line assurance to sample product files and verify that product features, pricing and support align to identified customer needs.
7
AI generatedStep 7 of 7
Record that this FCA publication introduces no new regulatory return or filing deadline, while treating it as relevant supervisory context for future FCA engagement.

Timeline

publication

Jul 27, 2022

FCA published PS22/9, setting out final rules and guidance for the new Consumer Duty.

publication

Jul 27, 2022

FCA published FG22/5 final non-Handbook guidance on the Consumer Duty.

effective date

Jul 31, 2023

Consumer Duty came into force for new and existing products or services open to sale or renewal.

effective date

Jul 31, 2024

Consumer Duty came into force for closed products and services.

publication

Jul 10, 2026

FCA published blog on why product design matters to consumers and findings from its review of design, monitoring and distribution under the Consumer Duty.

Sources

AI-generated analysis is based on the following primary sources. Always verify against the official publication.

BlogFinancial Conduct AuthorityJul 10, 2026
Why getting product design right really matters to consumers ↗
https://www.fca.org.uk/news/blogs/why-getting-product-design-right-really-matters-consumers
Policy statementFinancial Conduct AuthorityJul 27, 2022
PS22/9: A new Consumer Duty ↗
https://www.fca.org.uk/publications/policy-statements/ps22-9-new-consumer-duty
Finalised guidanceFinancial Conduct AuthorityJul 27, 2022
FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty ↗
https://www.fca.org.uk/publications/finalised-guidance/fg22-5-final-non-handbook-guidance-consumer-duty
Regulatory guidance webpageFinancial Conduct AuthorityDate not specified
Consumer Duty ↗
https://www.fca.org.uk/firms/consumer-duty

Related Evidence

Verified source support for this analysis

The evidence agent checks whether the drafted finding is supported by official publications and relevant public source material.

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