The Consumer Duty has four outcomes, sitting under one Consumer Principle and three cross-cutting rules. It applied to open products from 31 July 2023 and to closed products from 31 July 2024, and it requires an annual board report. The FCA is now consulting on narrowing its scope — which makes this a live area rather than a settled one.
The structure
It is built in three layers, all in PRIN 2A of the Handbook.
The Consumer Principle is Principle 12: "A firm must act to deliver good outcomes for retail customers."
Three cross-cutting rules sit under it, in PRIN 2A.2 — act in good faith towards retail customers; avoid causing foreseeable harm to retail customers; and enable and support retail customers to pursue their financial objectives.
Four outcomes then give it content:
- Products and services — their governance, design and distribution;
- Price and value;
- Consumer understanding;
- Consumer support.
Four is the answer to the question people search for, and the count is worth being precise about because the cross-cutting rules are sometimes miscounted as outcomes, producing a total of seven.
The deadlines
Implementation ran in two stages: 31 July 2023 for new and existing products and services open to sale, and 31 July 2024 for closed products and services.
Both have passed, so the live deadline is the recurring one. PRIN 2A.8.3R requires a firm to prepare a report for its governing body setting out the results of its monitoring and any actions required, and PRIN 2A.8.4R requires the governing body to review and approve it, confirm it is satisfied the firm is complying with the Duty, and assess whether future strategy is consistent with it — annually.
Note what the rule does and does not say. It says annually; it does not fix a calendar date. The first reports were due by 31 July 2024, which is why many firms anchor to July, but the obligation runs from the firm's own cycle rather than from a Handbook deadline.
What the FCA found in the board reports
This is the most useful evidence available on what "good" looks like, because it is drawn from real documents. The FCA reviewed the first reports from 180 firms, including 55 smaller firms, and published its findings in December 2024. It published year-two findings in April 2026, alongside a commitment to consult on distribution-chain rules and publish best practice on outcomes monitoring.
The recurring criticism is the one you would expect: reports that describe activity rather than outcomes. A board report that lists the projects undertaken, without data showing whether customers actually got good outcomes and what the firm did where they did not, does not satisfy a rule about monitoring results.
What has changed since
Two developments matter for anyone reading older guidance.
From February 2025, firms are no longer required to have a Consumer Duty board champion. The FCA's reasoning was that the Duty is now well embedded. Firms may keep the role voluntarily, and many have.
And the FCA has been reviewing the requirements themselves. FS25/2, announced in March 2025, set out plans to retire over 100 pages of outdated guidance for consumer finance, investment and mortgage firms, withdraw hundreds of supervisory publications, review prescriptive disclosure rules, and revisit the rules for firms with overseas customers.
The scope consultation
The significant open question is CP26/23, "Consumer Duty: scope and proportionality", published on 29 June 2026 with a consultation closing 18 September 2026. It proposes to:
- Remove business with genuinely non-UK customers from the Duty's scope;
- Clarify where the Duty applies at all;
- Clarify reliance between firms in distribution chains, and proportionality according to a firm's role;
- Explain the interaction with other product governance rules.
The FCA's framing is blunt: the Duty "was never intended to become a Wholesale Duty imposing on deals between sophisticated parties." Treat all of this as proposal rather than law — the consultation has only just closed and the outcome is not published.
What firms should actually do
Three things, in order of how often they are the real gap.
Fix the monitoring data before the report. The board report is a derived document. If the firm cannot show, by product and by customer group, what outcomes are being delivered and where they are worse, no amount of drafting will make the report adequate. This is usually a management information project rather than a compliance one.
Evidence price and value properly. This is the outcome most often addressed by assertion. A value assessment concluding that the price is fair, without showing the costs, the benefits and the comparison that led there, invites exactly the question it was meant to close.
Be honest in the report about what is not working. A report identifying a problem with a funded plan and a date reads far better than one concluding that everything is satisfactory — and the FCA has said as much about the reports it reviewed.
For firms newly in scope, the Duty now reaches deferred payment credit, where the FCA has said the consumer understanding and support outcomes are a core part of its approach. And the board-level governance expectations sit alongside the wider controls framework that Provision 29 now requires of listed companies.
Acumon supports regulated firms on governance, controls and the evidence behind regulatory reporting through corporate governance, internal audit and financial services audit work. If your next board report is due within six months and the outcomes data does not yet exist, that is the project to start now.