TO BE PUBLISHED April 2027
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The conference will consider next steps for the Consumer Duty. Areas for discussion include the Financial Conduct Authority’s proposed changes to the scope and proportionality of the Duty, the allocation of responsibilities across distribution chains, requirements for evidencing consumer outcomes, and approaches to fair value, vulnerability and consumer support.
Scope, proportionality & distribution chains
It will bring together stakeholders and policymakers to examine priorities as the FCA finalises its approach following its consultation on Consumer Duty scope and proportionality, with a Policy Statement and final rules expected in early 2027. Delegates will discuss implications of changes concerning non-UK business, retail and wholesale boundaries, reliance between firms, responsibilities within complex distribution chains and proportionate board reporting, alongside wider questions about the extent to which regulatory requirements can be simplified and applied proportionately while maintaining clear accountability and effective consumer protection.
Outcomes, fair value & supervision
The planned agenda will assess practical approaches to the measurement and evidencing of outcomes, including the use of data and management information, board reporting, customer cohort analysis, complaints and root-cause information, alongside options for identifying and addressing emerging harm. Attendees will consider what firms need to do to demonstrate fair value, consumer understanding and support, and the implications of the FCA’s developing supervisory and enforcement approach for governance, compliance and remedial action. Sessions will also consider implications of reform to the Financial Ombudsman Service and the wider redress framework being taken forward in the Financial Services and Markets Bill, currently progressing through Parliament.
Vulnerability, AI & cryptoassets
Further sessions will examine priorities for supporting consumers in vulnerable circumstances, including identification of differing needs, and the responsible use of vulnerability-related data. Discussion is expected on application of the Duty as products and customer journeys become increasingly digital, including AI-enabled services and automated decision-making, and on preparations for applying the Consumer Duty to cryptoasset firms under the new regulatory regime, which commences in October 2027. Delegates will consider implications of innovation for fair value, consumer understanding, accessibility and effective routes for complaints and redress.
Overview of areas for discussion
- policy direction, scope & proportionality:
- FCA Policy Statement anticipated in 2027, following CP26/23 - non-UK business, retail and wholesale boundaries, proportionality and transitional implications
- interaction with PROD 3 product-governance and Consumer Composite Investments disclosure requirements - reducing duplication - maintaining clear consumer protections
- distribution chains & accountability:
- reasonable reliance between firms - information-sharing and assurance - avoiding unnecessary oversight while preventing accountability gaps
- material influence - proposed principal and secondary manufacturer framework - responsibilities of manufacturers, distributors, advisers and intermediaries in complex arrangements
- outcomes monitoring, governance & evidence:
- moving from process metrics to evidence of customer experience - cohort analysis, complaints, root-cause information and identification of emerging harm
- board reporting - proposed removal of the stand-alone Duty report - management information, challenge and remedial action - showing how findings influence products, services and strategy
- fair value, understanding & consumer support:
- evidencing continuing fair value rather than completion of assessments - differential outcomes, fees and distribution costs - identifying and addressing poor value
- testing consumer understanding at key decision points - communications, digital journeys and support models - responding where misunderstanding is identified
- targeted support - application of the Duty under the new regulatory framework - the advice boundary and consumer outcomes
- vulnerability, inclusion & data:
- identifying differing needs - outcomes for consumers in vulnerable circumstances - accessibility, financial difficulty and tailored support
- use of vulnerability-related data - data protection, consent and governance - improving evidence without creating barriers to support
- supervision, enforcement & redress:
- FCA supervisory focus on Consumer Duty outcomes - skilled-person reviews, intervention and remediation - expectations where evidence of harm emerges
- FOS reform under the Financial Services and Markets Bill - treatment of the Duty under an adapted ‘fair and reasonable’ test - mass redress events and wider approaches to redress
- AI, digital journeys & cryptoassets:
- Mills Review - AI-enabled customer journeys - automated decision-making - personalisation, explainability, testing and human intervention - identifying new forms of harm
- final Consumer Duty guidance for cryptoasset firms - authorisation applications and preparation for the regime’s commencement in October 2027 - product design, communications, support and fair value
