More clarity on Consumer Duty responsibilities needed to avoid unnecessary duplication, warns TISA

September 21, 2026

TISA has called on the FCA to provide clearer guidance on how Consumer Duty responsibilities should be shared between firms, warning that uncertainty across complex distribution chains risks creating unnecessary duplication of outcomes monitoring rather than focusing resources where they can make the greatest difference to consumers.

In its response to the FCA’s CP26/23 Consumer Duty: scope and proportionality consultation, TISA welcomed moves towards a more targeted and proportionate approach. However, it called for more practical examples to help firms understand how responsibilities are shared across complex distribution chains and how the rules apply in practice.

Steve Latto, Policy Executive at TISA, commented:

“This proposed approach should allow firms to focus their energies on the distribution chain activities they control and where they can make the greatest difference to customers.

However, to unlock the benefits of this approach, firms need clarity and consistency to feel confident in taking that step. When multiple firms are involved in delivering a product or service, uncertainty around regulatory responsibilities can lead to duplicated compliance checks without delivering any additional protection for consumers.”

TISA is calling for greater clarity on:

Respective responsibities where several firms are involved in delivering the same product or service, particularly across platforms, administrators and outsourced providers.
The difference between controlling a product and helping to deliver it. A firm may have an important operational role and influence customer outcomes without controlling decisions such as who a product is designed for, what customers pay or how it is distributed.
When firms can reasonably rely on information provided by another business, helping to avoid unnecessary duplication of checks and information requests across the distribution chain.

Steve added:

“Additional clarity and more practical examples from the FCA would also help give firms greater confidence to put these changes into practice more consistently. Firms also need certainty that the FCA’s own supervisory approach will be consistent and reflect the same proportionate principles.

If the proposed approach is not supported by clarity and consistency, there is a risk firms do not make these simplifications, leaving resources which could focus on improving consumer outcomes tied up in unnecessary processes and duplication. We look forward to working with the FCA to ensure both firms and consumers see the benefit of a simplified consumer duty regime.”

TISA’s response also recommends that the FCA:

Support and improve more proportionate information sharing between firms, as gathering and exchanging Consumer Duty information has been a significant industry challenge. TISA outlined its plans to update its own best practice guidance to support a more targeted and practical approach.
Continue to update guidance as AI evolves and becomes more integrated, to ensure firms have clarity around where Consumer Duty applies and provide certainty around regulation to give them the confidence to innovate.
Provide further guidance on vulnerable customers as technology develops, including how firms should approach situations where consumers use AI assistants to make financial decisions on their behalf.

ENDS.

Notes to editors

A full copy of TISA’s response is available on request.
FCA Consultation Paper CP26/23, Consumer Duty – scope and proportionality, proposes changes intended to make the application of Consumer Duty more targeted, proportionate and predictable. The consultation closes 18^th September.
TISA is a not-for-profit membership organisation committed to improving the financial wellbeing of all UK consumers by working collectively with the financial services industry to deliver solutions and champion innovation, for the benefit of people, our industry, and the nation.
TISA has approximately 260 member firms involved in the supply and distribution of savings and investment products and associated services. Members include the UK’s major investment managers, retail banks, online platforms, insurance companies, pension providers, distributors, building societies, wealth managers, third party administrators, FinTechs, financial consultants, financial advisers, industry infrastructure providers and stockbrokers.