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Consumer Duty — the evidence year

The Consumer Duty has been live since July 2023, and closed-book products joined in July 2024. The reforms haven't moved. The FCA's expectation of evidence has — what worked in year one as a narrative report won't survive a year-two review. The pieces here cover the practical disciplines: outcomes monitoring, fair value assessment, MPS distribution-chain reconciliation, and vulnerable-customer adaptation.

Year 2 of Consumer Duty is the discipline year. Firms that put in the implementation work for the July 2024 deadline are now being asked to show — with data, with worked examples, with a board-level annual report — that the products and services they recommend continue to produce good outcomes for the consumers they were designed for. Most firms have something. Most don't have it in a form that would survive an FCA s.166.

The four pieces below are written for the partner or compliance lead at a UK IFA firm working through the second annual board report. Each is reviewed quarterly. Each cites primary FCA sources where claims rest on them. Read our editorial policy for the sourcing standards.

The cluster sits inside the broader Regulatory & Compliance hub. For the parallel reforms — Targeted Support going live 6 April 2026 and CP26/10 on Simplified Advice — see the regulatory hub.

About the authors

Eliot Jones (DipPFA, CCIBS) anchors the Consumer Duty cluster as a practising wealth manager. Matthew Hull (CFA, MSCI) reviews and authors on the portfolio-construction and MPS angles — a former CIO with deep experience of the chain-wide assessment Consumer Duty asks firms to assemble.