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The Financial Conduct Authority (FCA) have now published the final rules for Consumer Duty - PS22/9: A new Consumer Duty, alongside finalised guidance FG22/5. Firms have until 31 July 2023 to fully implement the Consumer Duty requirements for new and existing products and services, and until 31 July 2024 for closed products or services.

These three elements show how the new Consumer Duty is structured, it moves the overarching regulatory framework from a ‘principles’ based approach to a ‘rules’ based approach.

Consumer principle

  • Firms must act to deliver good outcomes for customers

Cross-cutting rules

  • Act in good faith towards customers
  • Avoid foreseeable harm to customers
  • Enable and support customers to pursue their financial objectives

Four outcomes

  • Products and services
  • Price and value
  • Consumer understanding
  • Consumer support

Part 1 – What does it all mean and how does it fit in with research and suitability processes?

On this session, hosted by Pru’s Vince Smith-Hughes and Andy Nash, who were joined by special guests Mark Polson and Alison Gay from the lang cat, a leading independent platform. They looked at what the Consumer Duty means for advisers/advisory firms overall, and what else might be needed when it comes to research and suitability.

Part 2 - How can technology help you with Consumer Duty?

On this session, hosted by Pru’s Colin Simmons, who was joined by special guest Nick Eatock, CEO and Co-Founder of Intelliflo. They focused on how technology can help you meet the new requirements, what’s already available and what further developments and actions might be needed. 

Part 3 – Platforms and servicing – meeting the Consumer Duty requirements

On this session, hosted by Vince Smith-Hughes, he was joined by special guest Heather Hopkins and John Allen. They looked at the due diligence and governance that needs to be considered when researching a platform, and what changes may be needed in the future.

Part 4 - Regulatory Landscape with the experts - Peter Lovegrove, Ricky Nuttall and Ross Liston

On this session we discussed the imminent FCA Consumer Duty rules and guidance with three experts, Peter Lovegrove of Grant Thornton, Ricky Nuttall of Simplybiz and Ross Liston of Bankhall.

FCA Consumer Duty – a closer look at the four outcomes

Outcome 1: Products and Services

The FCA wants all products and services for retail customers to be fit for purpose. 


Outcome 2: Price and Value

The FCA’s second Consumer Duty outcome is based on its assertion that consumers experience harm where they don’t get value for their money.

Outcome 3: Consumer Understanding

The FCA wants consumers to be given the information they need, at the right time, and presented in a way they can understand.

Outcome 4: Consumer Support

This relates to how a firm supports its customers using its products and services.


Related insights

A new customer duty – but what will it mean for advisers?

The ‘cross cutting’ rules set out how firms should act to deliver good outcomes and therefore provide greater clarity on the expectations required.


PruFund since Pension Freedoms begun – how has  it worked?

When pension freedoms were introduced over six years ago the take up of drawdown increased significantly,  with customers keen to take advantage of accessing their pension pots without constraint. 

Case study: Different stages of retirement planning

When pension freedoms were introduced over six years ago the take up of drawdown was increased significantly, with consumers keen to take advantage of accessing their pension pots without constraint. 

Marrying Consumer Duty and client income

With the introduction of pension freedoms it is clear that many people have turned to drawdown as their retirement income vehicle of choice.

Consumer Duty E-Book

The Consumer Duty final rules have arrived and preparations need to start now in order to meet the FCA’s challenging deadlines.


Consumer Duty action plan

This sample action plan has been designed to help firms record their approach, and prompt thoughts and ideas about how they can demonstrate that they put their clients at the heart of their business. This plan covers the 'Consumer Principle’, ‘Cross Cutting rules’ and ‘The Products and Services’ outcome.

Independent AKG review

PruFund structure, investment management and governance processes.

Due diligence and third party reports

The FCA’s paper TR16/1 Assessing Suitability: Research and due diligence of products and services, requires advisers to demonstrate they have the appropriate information and evidence on file for their client investment recommendations.


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PruFund client support information

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