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What’s this about?
The FCA has published feedback on its Call for Input regarding simplifying its requirements following the introduction of Consumer Duty aimed at reducing the regulatory burden for businesses. The proposed action plan details actions that are already in train, plus other changes they intend make across various rules and guidance, including mortgages, consumer credit, general insurance and funeral plans, retail banking, asset managers, and the safeguarding of client assets.
Our Head of Financial Regulation, Amanda Hulme says...
"There is much to be welcomed in the FCA’s proposed plans, and the direction appears sensible and pragmatic. However, firms should not interpret these changes as a reduction in regulatory expectations. Instead, they provide greater flexibility to achieve good outcomes for their customers. This increased flexibility will require firms to demonstrate how they are meeting both customer outcomes and regulatory expectations."
The points not to miss...
The aim of the changes that the FCA is proposing are:
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Provide firms with more flexibility to tailor their approach to customers and how to deliver good outcomes
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Increase the predictability of the FCA’s priorities
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Increase efficiency of firms in meeting regulatory expectations, but still delivering good outcomes
How the FCA will deliver it action plan:
The FCA plans to use an accelerated consultation process to act on the proposals in the paper. Additionally, where feedback was mixed on other changes the FCA should make, the FCA will gather further views to identify areas needing more significant change.
Key actions the FCA is committed to take:
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Mortgages
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May 2025 |
The FCA will consult on proposals to make re-mortgaging easier for consumers and reduce borrowing costs through term reductions. Also, the consultation will make it easier for consumer to discuss their mortgage options outside of a regulated advice process. |
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June 2025 |
The FCA will publish a discussion paper covering areas such as:
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Consumer credit |
Within 12 months |
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General Insurance & Funeral Plans
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Summer 2025 |
The FCA intends to consult on:
In addition, the FCA will also seek views on:
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TBC |
The FCA will review reporting requirements that were introduced under its general insurance pricing practices intervention. |
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Retail Banking |
TBC |
The FCA intends to review retail banking disclosures to increase flexibility on how information is communicated to customers and, where appropriate, remove prescriptive disclosure requirements. The review will include consideration of the summary box requirements for savings accounts. |
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Investments |
2025 (H2) |
The FCA plans to consult on changes to the requirement for asset managers to report annually on their value assessments, to align it more closely with the FCA’s general approach to value assessments. |
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Client Asset Rules |
2025 (H2) |
The FCA will consult on updating requirements in the Client Assets sourcebook (CASS) related to:
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Other Handbook changes
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TBC |
The FCA will be reviewing core definitions in its Handbook, with a view to having consistent definitions across the Handbook (e.g. currently Handbook as different definitions of retail and SME customer for different parts of the Handbook). |
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2025 |
The FCA will publish and pilot guides for smaller firms for requirements for different sectors, to help them understand their requirements when implementing outcome focussed regulation. |
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Q2 2025 |
The FCA plans to review and retire historical sector communications (Dear CEO letters, portfolio letters, multi-firm review thematic reviews and newsletters) that pre-dated its 2022-25 strategy. |
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2025 (H2) |
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Summer 2025 |
The FCA will introduce a feedback tool which will enable firms to submit evidence when a rule is not working as intended. |
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TBC |
Review of the feedback tool that enables firms to submit evidence when a rule is not working as intended. |
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Consumer Duty |
TBC |
The FCA plans to engage with stakeholders on how it can provide more clarity on:
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At a glance...
| Publication link: | https://www.fca.org.uk/publications/feedback-statements/fs25-2-action-plans-reviewing-requirements-consumer-duty |
Want to discuss? Nikesh Shah Ben Cooper |
| Publication date: | 25/03/25 | |
| Who has published it? | FCA | |
| Publication type: | Feedback Statement | |
| Any key dates? | N/A | |
| What's it relevant to? | regulatory change; mortgage regulation; Consumer Duty; general insurance regulation; funeral plan regulations; retail banking regulation; consumer credit; CASS; |
This publication is intended for general guidance and represents our understanding of the relevant law and practice as at March 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.
Date published
31 March 2025
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