Author Archive

The FCA’s latest review reveals a clear message: while firms have made progress on Consumer Duty, many still fall short on true customer understanding. From jargon-heavy communications to ineffective testing, the gap between compliance and clarity remains. Here’s what the FCA found and what it means for firms.

The FCA’s latest review reveals a clear message: while firms have made progress on Consumer Duty, many still fall short on true customer understanding. From jargon-heavy communications to ineffective testing, the gap between compliance and clarity remains. Here’s what the FCA found and what it means for firms.

The FCA is raising the bar on Consumer Duty board reporting, making clear that narrative assurance alone is no longer sufficient. Firms must now evidence, with clarity and rigour, how they monitor outcomes, challenge performance, and take action, regardless of their size.

The FCA’s 2026 Insurance Regulatory Priorities letter signals a sharp focus on distribution oversight, behavioural design and vulnerable customers. From friction in sales journeys to outsourced claims governance, firms are expected to demonstrate stronger control, clearer accountability and measurable consumer outcomes.

The FCA’s interim consumer research into the pure protection market highlights persistent gaps in understanding, engagement and perceptions of value, particularly in non-advised journeys. While no immediate action is required, the findings clearly signal the FCA’s direction of travel and raise important questions for firms around Consumer Duty outcomes, fair value assessments and distribution oversight as the market study progresses.

From January 2026, the UK will move to a single, centralised sanctions list. A major shift in the post-Brexit sanctions framework. Firms will need to update screening systems, policies, and contractual references to stay compliant. Here’s what’s changing, why it matters, and how to prepare.

Underwriting evolution, technical expertise, digitalisation and regulatory influence are not separate themes. They are connected by a growing expectation that accountability is clear, demonstrable and built into how the market operates.

The FCA has published PS25/23 and confirmed a major expansion of COCON to non-banks from 1 September 2026. Non-financial misconduct is now firmly established as a regulatory concern, and firms will be expected to evidence fair, consistent and well-governed decision-making in practice.

In December 2025, the FCA published its Quarterly Consultation Paper No. 42 (CP25/24), proposing to decommission a number of regulatory returns submitted by general insurance intermediaries. While the proposals reduce duplicative reporting, firms will still be expected to maintain robust internal MI and governance to demonstrate fair value and good customer outcomes under the Consumer Duty.