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Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
The FCA’s 2026 Consumer Duty file is now a stack of official artefacts, not a new go-live: smaller-firm board-report insight on 24 February, a year-2 board-reports blog on 16 April, CP26/23 on scope and proportionality (open 29 June, comments by 18 September 2026), and an outcomes-monitoring blog on 27 July. The Duty itself has been in force since 31 July 2023, and for closed products since 31 July 2024. If you own board reporting, MI or distribution-chain oversight, the job this summer is the third-cycle report and a live consultation response — CP26/23 is still open.
On 24 February 2026 the FCA updated its board-reports good and poor practice page with extra insight for smaller firms. On 16 April 2026 it published a year-2 blog: boards are more active, action plans have owners, data is broader — and third-cycle reports are “on the horizon”. Weak spots in that review still matter for the next pack: data that does not show outcomes, thin third-party monitoring, board minutes that do not record challenge, and light treatment of consumer understanding and support.
CP26/23 opened on 29 June 2026. It would remove business with non-UK customers from the Duty’s scope, make it clearer where the Duty applies, clarify when firms in a distribution chain can rely on each other, and explain the interaction with other product-governance rules. Comments close on 18 September 2026. A policy statement and any new rules are expected in Q1 2027. Do not treat the consultation as closed. A companion FCA blog on wholesale firms sits with CP26/23; use it as policy colour, not as a dated event.
On 27 July 2026 the FCA published an outcomes-monitoring blog and a matching good-practice page. The test is simple: what the information told you, what you did, and whether the action improved outcomes. Smaller firms can do this with a short set of indicators. You do not wait for Q1 2027 to fix that.
| Business type / activity | What is in play | Immediate operational task | Official reference |
|---|---|---|---|
| Smaller retail firms | 24 February smaller-firm update; proportionate outcomes monitoring | Critical friend or named Duty lead; a short MI set (complaints, feedback, service standards, file checks); document who owns the Duty if there is no board committee | Board reports: good practice (smaller-firm update 24 February 2026) |
| Larger retail firms (banks, insurers, investments, consumer finance) | Year-2 findings plus 27 July outcomes monitoring | Third-cycle board report with outcomes-linked MI, named actions, and minutes that show challenge | Year 2 board reports blog, 16 April 2026; outcomes-monitoring blog, 27 July 2026 |
| Wholesale firms in a retail distribution chain | CP26/23 reliance and scope proposals — still open | Map where you genuinely shape retail outcomes; do not drop monitoring while the CP is open | CP26/23; wholesale companion blog |
| Manufacturers and distributors | Information-sharing across the chain | What you send, what you receive, and how poor outcomes at a partner become an action | Year-2 blog; outcomes monitoring: good practice |
| Firms serving non-UK retail customers | CP26/23 territorial proposal to take that business out of scope | Customer-book split (UK retail vs non-UK) for the consultation response; current rules still apply until any PS | CP26/23 (opens 29 June 2026; closes 18 September 2026; PS Q1 2027) |
| Closed-product books | Duty in force for closed products from 31 July 2024 | Keep closed products in the board report; do not treat them as a finished 2024 project | Board-reports page (Duty 31 July 2023; closed products 31 July 2024) |
Operational tip: CP26/23 is a consultation. It does not change the Handbook this week. Build the response and the third-cycle report in parallel.
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Size the firm against the 24 February material | If you are small: Duty lead, critical friend, proportionate MI, record of who is accountable. If you are not: do not use “we are small” as the gap. | Board-reports page, section 2, 24 February 2026 |
| 2 | Gap the last board report against year 2 | Four tests: data linked to outcomes; third-party monitoring; documented board challenge; consumer understanding and support, not only products and value | Year-2 blog, 16 April 2026 |
| 3 | Define good outcomes by journey | Plain-language outcomes at join, use and leave, with indicators and thresholds you can explain | Outcomes-monitoring good-practice page; 27 July blog |
| 4 | Build the third-cycle report plan | Owners, data cuts, vulnerability segmentation, action tracker with dates, board-minutes template for challenge | PRIN 2A.8 as described on the board-reports page; year-2 blog |
| 5 | Map CP26/23 to the book | Non-UK customers; distribution-chain reliance; product-governance overlap; wholesale activities that do not shape retail outcomes | CP26/23 |
| 6 | Decide the consultation response | Response, or a documented decision not to respond, by 18 September 2026 | CP26/23 (“feedback … by 18 September 2026”) |
| 7 | Third-party and outsourcing MI | What you get from TPAs, brokers and outsourcers; escalation when outcomes fail | Year-2 blog; outcomes-monitoring good-practice page |
| 8 | Do not wait for the PS | Q1 2027 is the expected policy statement window. No day inside that quarter is given. Fix MI and minutes now. | CP26/23 next steps |
GRT Consulting supports operational teams with:
Start with the free FCA Consumer Duty diagnostic if you need a first cut.
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