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FCA Consumer Duty and Estate Planning Services: What Advisors Must Do

· 20 min

Executive Summary

The FCA Consumer Duty (Principle 12 and PRIN 2A), fully operational since 31 July 2024, imposes materially elevated obligations on advisory firms delivering estate planning services. Estate planning sits at a distinctive intersection of Consumer Duty risk: information asymmetry is acute, vulnerability prevalence is inherently high, and the consequences of poor outcomes may not materialise for years. This analysis maps each of the four Consumer Duty outcomes to specific estate planning activities, addressing the compliance implications of the residence-based inheritance tax regime enacted from 6 April 2025 and the confirmed pension death benefit taxation changes from April 2027. Drawing on FCA multi-firm review data, fair value framework findings, and vulnerability identification gaps across wealth management, the article provides a practical regulatory compliance framework for advisory firms seeking to embed the Duty within their estate planning propositions.

1. The Consumer Duty Framework Applied to Estate Planning

1.1 Regulatory Architecture

The Consumer Duty was introduced under PS22/9, exercising the FCA's general rule-making power under section 137A of the Financial Services and Markets Act 2000.1 Principle 12 requires that "a firm must act to deliver good outcomes for retail customers," replacing the more passive obligations under Principles 6 and 7 where Principle 12 applies.2 The three cross-cutting obligations under PRIN 2A.2 require firms to act in good faith toward retail customers, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives.3

The four outcome rules under PRIN 2A.3 through 2A.6 address products and services, price and value, consumer understanding, and consumer support respectively. PRIN 2A.9 further requires firms to define, monitor, evidence, and stand behind the outcomes their customers experience.4 The Duty came into force for open products and services on 31 July 2023, extending to closed books on 31 July 2024.2

The significance of this framework for estate planning lies in the shift from a conduct-of-business model focused on process compliance to an outcomes-based model requiring demonstrable evidence of good results. Under the pre-Duty regime, an advisory firm could satisfy its obligations by following prescribed suitability processes. Under the Duty, the same firm must evidence that its estate planning clients actually achieve good outcomes -- a materially higher bar that requires service-specific analysis rather than generic compliance overlays.

1.2 Why Estate Planning Services Are Distinctly Exposed

Estate planning advisory services present a convergence of factors that elevate Consumer Duty risk beyond that of standard investment advice. Three characteristics merit particular attention from compliance officers.

First, the outcome horizon for estate planning advice is measured in years or decades. Unlike investment recommendations where performance data provides relatively proximate feedback, the adequacy of estate planning advice may only become apparent upon death, incapacity, or a major life event. This complicates the monitoring obligations under PRIN 2A.9, as firms cannot rely on periodic performance benchmarking to evidence good outcomes. A trust structure recommended in 2024 may not be tested until the settlor's death in 2040, by which time legislative, fiscal, and family circumstances may have changed substantially.

Second, information asymmetry is especially pronounced. Clients engaging in estate planning typically lack the technical knowledge to evaluate advice on trust structures, inheritance tax mitigation, or cross-border succession. This places heightened demands on the consumer understanding outcome under PRIN 2A.5.5 Unlike investment advice, where clients may have some basis for comparison through past experience or publicly available performance data, estate planning advice is often a once-in-a-lifetime engagement with limited scope for the client to independently validate the recommendations received.

Third, vulnerability prevalence is inherent rather than incidental. Estate planning engagement frequently arises from bereavement, ageing, diagnosis of serious illness, or cognitive decline -- all characteristics of vulnerability under FG21/1.6 The FCA's multi-firm work has revealed that significant proportions of wealth management firms fail to identify any vulnerable customers, with approximately a quarter of portfolio managers and half of stockbroking firms reporting zero clients in vulnerable circumstances.78

1.3 The FCA Perimeter: A Critical Distinction

Advisory firms must maintain precision about which estate planning activities fall within the FCA's regulatory perimeter. Estate planning advice involving specific investment recommendations -- such as IHT-efficient portfolio construction, whole-of-life insurance policies written in trust, or pension death benefit nomination strategies -- constitutes regulated activity under COBS 9 and 9A.9 Trust establishment involving financial products may also be regulated.

Conversely, will-writing, probate advice, and general tax planning not involving financial product recommendations generally fall outside FCA regulation. The Consumer Duty obligations under PRIN 2A apply to "retail market business" and the present analysis is confined to estate planning activities within that perimeter. Firms offering holistic estate planning propositions that straddle the regulatory boundary must ensure their compliance frameworks distinguish clearly between regulated and unregulated service elements. Failure to maintain this distinction risks either under-applying Consumer Duty obligations to regulated activities or, conversely, creating an inaccurate impression that unregulated services carry FCA-level consumer protections.

2. Products and Services Outcome: Defining the Estate Planning Proposition

2.1 Target Market Identification

PRIN 2A.3 requires manufacturers to specify target markets at a sufficiently granular level and prohibits distributors from distributing products outside the identified target market.10 For advisory firms operating as distributors of estate planning-related financial products, this obligation demands more than generic client categorisation.

Estate planning services encompass clients with fundamentally different needs: a recently bereaved spouse requiring immediate death benefit nomination review presents a materially different target market from a high-net-worth individual undertaking proactive IHT mitigation. Firms relying on a single, broadly defined target market for their estate planning proposition risk failing to meet the granularity expectation under PRIN 2A.3. A robust target market definition for estate planning services should segment by, at minimum, the nature of the planning trigger (proactive planning, bereavement, incapacity), the complexity of the estate (single jurisdiction versus cross-border, business assets, agricultural holdings), and the client's existing arrangements (first-time planning versus review of legacy structures).

The FCA's ongoing advice services multi-firm review, examining 22 of the largest advice firms, found that ongoing advice now represents 80% of all advice revenue, up from 60% in 2016, with 90% of new clients placed into ongoing advice arrangements.11 Where estate planning forms part of an ongoing advice proposition, firms must ensure the target market definition addresses estate planning-specific needs rather than subsuming them within a generic ongoing advice description.

2.2 The Residence-Based IHT Regime: A Proposition Review Trigger

The enactment of the residence-based IHT regime from 6 April 2025 -- introduced by sections 44 to 46 of the Finance Act 2025 (c. 8), which insert new sections 6A to 6C into the Inheritance Tax Act 1984 -- replaced the domicile-based system with a long-term resident test of 10 out of the previous 20 tax years, with departure tail provisions of 3 to 10 years.12 This legislative change creates a direct obligation under the products and services outcome.

Advice given under the prior domicile-based regime may now be unsuitable for clients whose IHT exposure has changed under the new residence test. The cross-cutting obligation to avoid foreseeable harm under PRIN 2A.2 requires firms to identify proactively where existing estate planning advice may no longer reflect the client's regulatory position.3 Compliance teams should treat the regime change as a trigger for systematic back-book review of estate planning recommendations, particularly for internationally mobile clients and those who may meet or cease to meet the long-term resident definition.

The regime change also affects trust taxation: trust IHT status now depends on the settlor's residence status at the date of the relevant charge, not domicile at the time of settlement. Advisory firms that recommended trust structures under the domicile-based system should assess whether those structures remain appropriate under the residence-based framework and communicate any changes in IHT exposure to affected clients.

2.3 Suitability Review Delivery Rates

The FCA's multi-firm review found that suitability reviews were delivered in approximately 83% of cases, with 15% of clients declining or not responding and fewer than 2% of cases where firms made no effort to conduct a review.11 These figures raise a specific question for estate planning: where estate planning sits within a broader ongoing advice proposition, compliance officers should verify whether suitability reviews adequately address the estate planning elements or focus predominantly on investment portfolio performance.

The FCA's assessing suitability review provides further context, finding that 93.1% of advice assessed was suitable, 4.3% was unsuitable, and 2.5% was unclear.13 Material information gaps -- including missing risk assessments or investment objectives -- resulted in advice being treated as unsuitable regardless of its substantive appropriateness. Estate planning advice that lacks documented evidence of a client's estate composition, family circumstances, or domicile and residence status is exposed to this risk. The FCA's Investment Advice Assessment Tool, updated in June 2025, reflects the methodology the regulator applies when assessing suitability in supervision and enforcement -- advisory firms should consider adopting a comparable framework for their estate planning suitability documentation.14

3. Price and Value: Fair Value Assessment for Advisory Services

3.1 The Methodological Challenge

PRIN 2A.4 requires that distribution arrangements are consistent with fair value, considering the cumulative impact of remuneration across the distribution chain.15 For advisory firms, applying fair value assessment to estate planning services presents distinct challenges.

The "benefit" side of the fair value equation in estate planning encompasses risk mitigation (reducing exposure to contested wills, failed trusts, or IHT liabilities), tax efficiency (lawful reduction of inheritance tax payable), and family governance outcomes (ensuring assets transfer according to the client's intentions). These benefits resist the quantitative measurement frameworks that apply to investment product performance. An estate plan that prevents a GBP 400,000 IHT liability through effective use of the nil-rate band, residence nil-rate band, and spousal exemption delivers measurable value -- but that value only crystallises on death and may not be observable during the advisory relationship.

The FCA's December 2025 review of fair value frameworks found that some firms' analysis was limited to competitor benchmarking rather than substantive value assessment.16 Best practice, according to the FCA, requires firms to clearly state whether fair value is delivered for each product or service with supporting rationale. For estate planning, this demands evidence that goes beyond fee comparison: documentation of the complexity of advice provided, the range of estate planning issues addressed, and the quality of ongoing review.

3.2 Distribution Chain Considerations

Where advisory firms recommend trust structures, insurance products, or investment vehicles manufactured by third parties as part of an estate planning strategy, PRIN 2A.4 requires consideration of the cumulative cost across the distribution chain.15 A whole-of-life policy written in trust to meet an anticipated IHT liability involves the advisory firm's fees, the product manufacturer's charges, and potentially trustee administration costs. The fair value assessment must consider whether the aggregate cost represents fair value relative to the benefit the client receives.

This analysis becomes more complex where the estate planning advice itself is bundled within an ongoing advice fee. Firms charging a percentage-based ongoing fee must demonstrate that the estate planning component of the service delivers fair value at the marginal cost to the client, rather than treating it as an ancillary benefit that subsidises the fee for investment management. The FCA's fair value review explicitly cautioned against assessments that fail to isolate the value delivered by each service component -- a finding with direct implications for firms bundling estate planning within broader wealth management propositions.16

3.3 Practical Framework for Fair Value Evidencing

Advisory firms seeking to evidence fair value for estate planning services should consider a framework that addresses four dimensions. First, complexity assessment: documenting the technical complexity of each client's estate planning needs, including the number of jurisdictions involved, the range of asset classes, and the presence of business property or agricultural property. Second, outcome measurement: recording measurable outcomes where possible, such as estimated IHT savings from implemented strategies, successful trust registrations, or completion of lasting power of attorney arrangements. Third, service scope documentation: maintaining clear records of the estate planning activities undertaken as part of the advisory relationship, distinct from investment management activities. Fourth, periodic review: ensuring that the fair value assessment is revisited when circumstances change, including legislative changes such as the residence-based IHT regime.

No FCA guidance specifically addresses how to conduct fair value assessments for advisory services as distinct from product manufacturing. The framework above therefore represents emerging best practice rather than a regulatory prescription. However, firms that can demonstrate a structured, evidence-based approach to fair value assessment for estate planning services will be better positioned to withstand supervisory scrutiny than those relying on generic, firm-wide assessments.

4. Consumer Understanding, Vulnerability, and Support

4.1 Consumer Understanding in Estate Planning

PRIN 2A.5 requires that communications are made in good time, through appropriate channels, and in a way that supports effective decision-making.5 The FCA expects firms to ask whether customers understand key information rather than merely providing it.

Estate planning involves concepts that are inherently difficult for consumers to evaluate: the distinction between absolute and discretionary trusts, the interaction between the nil-rate band and the residence nil-rate band, the implications of the seven-year rule for lifetime gifts, and the tax treatment of pension death benefits. The consumer understanding obligation therefore requires advisory firms to go beyond written suitability reports and actively verify client comprehension. Practical approaches include structured follow-up conversations confirming the client can articulate the key features and risks of recommended arrangements, documented comprehension checks at each stage of implementation, and clear explanations of what circumstances would trigger a need to review the arrangements.

The confirmed change to pension death benefit taxation from April 2027 -- bringing pension pots within the scope of income tax on death -- presents a specific consumer understanding challenge.17 Estate planning advice that incorporates pension death benefit nominations must communicate the impact of this change clearly, particularly for clients whose existing arrangements were structured on the basis that pension pots fell outside the IHT estate. Under PRIN 2A.5, firms have an obligation not merely to inform but to ensure understanding. Given that pension death benefit treatment has been a cornerstone of estate planning strategy for many clients, the communication challenge is significant: clients must understand both the change itself and its implications for their specific arrangements.

4.2 Vulnerability Identification: The Wealth Management Gap

The FCA's multi-firm work on vulnerability identification exposed a striking gap in wealth management. Approximately a quarter of portfolio managers with retail clients reported zero vulnerable clients, while half of stockbroking firms failed to identify any customers in vulnerable circumstances; among individual stockbrokers the figure reached approximately 69%.78 Only 4 in 10 consumers with vulnerability characteristics disclosed their circumstances to any financial services provider.18

These figures are particularly problematic for estate planning services, where vulnerability triggers are not incidental but structural. Bereavement is the precipitating event for probate-related advice. Ageing and cognitive decline are common contexts for lasting power of attorney discussions. Serious illness diagnosis frequently motivates accelerated estate planning. Under FG21/1, firms are expected to understand the needs of customers in vulnerable circumstances, and the Consumer Duty requires that support provided to a person authorised by a retail customer (such as a power of attorney holder) matches the support available to the customer directly.6

Advisory firms whose vulnerability identification processes were designed for investment management contexts must recalibrate for estate planning. A vulnerability framework that relies on transactional triggers (unusual withdrawal patterns, investment switches) will fail to capture the vulnerability characteristics inherent in estate planning engagement. Compliance teams should implement estate planning-specific vulnerability indicators, including recent bereavement, referral by a third party acting under power of attorney, expressed concerns about cognitive capacity, and family conflict over estate distribution. The low disclosure rate -- only 4 in 10 consumers with vulnerability characteristics informing their provider -- underscores the need for proactive identification rather than reliance on client self-reporting.18

4.3 Consumer Support: Bereavement and Power of Attorney Processes

The consumer support outcome under PRIN 2A.6 requires firms to include appropriate friction to mitigate harm risk and ensure no unreasonable barriers throughout the product or service lifecycle.19 The FCA's multi-firm review of retail banks' treatment of customers in vulnerable circumstances -- reviewing bereavement and power of attorney customer journeys -- identified fragmented CRM systems causing customers to repeat information, and found that app-based and online banking were frequently unavailable for attorneys acting on behalf of clients.20

While this review focused on banking, the findings are directly relevant to advisory firms handling estate planning. Bereavement processes that require a surviving spouse or executor to navigate multiple departments, repeat their circumstances to each, and wait extended periods for account access create foreseeable harm under PRIN 2A.2. Good practice identified by the FCA includes centralised vulnerability data systems that ensure client circumstances are visible across all touchpoints, and the use of technology-assisted vulnerability identification to supplement manual processes.20

5. Outcomes Monitoring, Evidence, and Governance

5.1 Defining Good Outcomes for Estate Planning

PRIN 2A.9 requires firms to define, monitor, evidence, and stand behind the outcomes their customers experience, identifying where customers or groups experience poor outcomes and taking appropriate remedial action.4 For estate planning, defining "good outcomes" requires service-specific metrics distinct from investment performance.

Good outcomes in estate planning may include: advice that remains suitable following legislative changes (such as the residence-based IHT regime); successful implementation of recommended strategies (trust establishment, policy placement, nomination completion); client comprehension of their estate planning position as evidenced through documented discussions; and timely review of estate planning arrangements when triggered by life events or regulatory change.

Poor outcomes requiring remedial action may include: advice that has become unsuitable due to the IHT regime change and has not been reviewed; incomplete implementation where recommended actions were not followed through; and estate planning elements of ongoing advice propositions that have not been reviewed within the agreed service period. Firms should establish clear escalation protocols for identifying and remediating poor estate planning outcomes, recognising that the long outcome horizon means harm may accumulate gradually rather than manifest in a single event.

5.2 Board Reporting and Governance

Since 27 February 2025, the FCA no longer expects firms to designate a Consumer Duty Board champion, though firms may retain the role.21 This change should not be interpreted as a relaxation of governance expectations. The FCA's position is that the Duty should be sufficiently embedded within firm culture and governance structures that a dedicated champion is unnecessary.

For estate planning services, board reporting should include specific metrics: the proportion of clients with estate planning needs who have received a review within the agreed service period; vulnerability identification rates within the estate planning client cohort; fair value assessment outcomes for estate planning service elements; and consumer understanding measures such as client feedback on comprehension of estate planning recommendations.

The FCA's good practice guidance on Consumer Duty board reports noted that one wealth management firm removed minimum fees from certain products as a direct result of board-level fair value analysis.21 Similar scrutiny applied to estate planning fees could identify instances where fixed minimum charges create poor value for clients with straightforward estate planning needs.

5.3 The Forward Regulatory Landscape

Several forthcoming developments will shape Consumer Duty compliance for estate planning services. The FCA has confirmed it will consult on removing business with non-UK customers from Consumer Duty scope in Q2 2026, which could affect firms advising internationally mobile clients on estate planning.22 The targeted support framework under PS25/22, effective from 6 April 2026, will enable directly authorised firms to provide suggestions to groups with common characteristics based on reasonable assumptions -- potentially opening a pathway for estate planning guidance below the full advice threshold.23

Additionally, the FCA plans to consult on simplifying and consolidating investment advice rules in early 2026, and is consulting on allowing individuals with investable assets exceeding GBP 10 million to be categorised as elective professional clients without full qualitative assessment under CP25/36.24 Each of these developments has implications for how estate planning services are structured and delivered under the Consumer Duty framework. The client categorisation consultation is particularly relevant: if high-net-worth individuals can be categorised as elective professional clients more readily, this could reduce the Consumer Duty obligations applicable to estate planning advice provided to that cohort, while simultaneously raising questions about whether reduced protections are appropriate for complex, long-horizon estate planning decisions.

Conclusion

The Consumer Duty represents a fundamental reframing of regulatory obligation -- from avoiding harm to delivering demonstrably good outcomes. For estate planning services, this shift has specific and substantial implications that generic, firm-wide compliance programmes may fail to address. The convergence of the residence-based IHT regime from April 2025, the confirmed pension death benefit taxation changes from April 2027, and the FCA's intensified scrutiny of vulnerability identification in wealth management creates an environment where estate planning propositions require dedicated Consumer Duty analysis.

Advisory firms that treat the Duty as an opportunity rather than a burden -- embedding outcome-specific monitoring, recalibrating vulnerability frameworks for estate planning contexts, and developing fair value methodologies that capture the distinctive benefits of estate planning advice -- will differentiate their propositions in an increasingly scrutinised market. Those that subsume estate planning within generic compliance frameworks risk both regulatory action and client harm of the kind the Duty was designed to prevent. The forward regulatory landscape, with consultations on scope, simplified advice, and client categorisation expected throughout 2026, will further shape the obligations -- but the foundational requirement remains unchanged: firms must evidence that their estate planning clients achieve good outcomes.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: FCA regulatory compliance, estate planning advisory services, consumer vulnerability, fair value assessment

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Evaluate how each of the four FCA Consumer Duty outcomes applies to specific estate planning service activities within the regulatory perimeter
  2. Assess the compliance implications of the residence-based IHT regime (from 6 April 2025) for existing estate planning advice under PRIN 2A.2 cross-cutting obligations
  3. Distinguish between appropriate and insufficient fair value assessment methodologies for estate planning advisory services, applying the FCA's December 2025 review findings
  4. Design vulnerability identification frameworks calibrated to estate planning engagement triggers, including bereavement, cognitive decline, and power of attorney contexts

FCA Competency Framework Mapping

  • TC 2.1.1: Ability and knowledge to advise on and arrange appropriate products and services (Training and Competence Sourcebook)
  • CII/PFS CPD: Regulatory and compliance (Consumer Duty application to advisory services)
  • CII/PFS CPD: Estate planning and wealth management (vulnerability identification and fair value assessment)

Reflective Questions

  1. How would an estate planning-specific vulnerability identification framework differ from the investment management-focused approach currently in operation within advisory practices?
  2. What evidence would demonstrate that estate planning elements of an ongoing advice proposition deliver fair value independently of investment management services?
  3. How should compliance teams prioritise the back-book review of estate planning advice given under the domicile-based IHT regime, and what criteria would identify the highest-risk client cohorts?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. Financial Services and Markets Act 2000, s.137A (as amended). https://www.legislation.gov.uk/ukpga/2000/8/section/137A ↩

  2. FCA Policy Statement PS22/9: A new Consumer Duty (July 2022). https://www.fca.org.uk/publications/policy-statements/ps22-9-new-consumer-duty ↩ ↩2

  3. FCA Handbook, PRIN 2A.2 -- Cross-cutting obligations. https://handbook.fca.org.uk/handbook/PRIN/2A/2.html ↩ ↩2

  4. FCA Handbook, PRIN 2A.9 -- Monitoring of consumer outcomes. https://handbook.fca.org.uk/handbook/PRIN/2A/9.html ↩ ↩2

  5. FCA Handbook, PRIN 2A.5 -- Consumer understanding outcome. https://handbook.fca.org.uk/handbook/PRIN/2A/5.html ↩ ↩2

  6. FCA Finalised Guidance FG21/1: Guidance for firms on the fair treatment of vulnerable customers (February 2021). https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf ↩ ↩2

  7. FCA, Delivering good outcomes for customers in vulnerable circumstances (2025). https://www.fca.org.uk/publications/good-and-poor-practice/delivering-vulnerable-customers ↩ ↩2

  8. FCA speech by Graeme Reynolds, "Vulnerability is not a buzzword" (24 October 2024). https://www.fca.org.uk/news/speeches/vulnerability-not-buzzword ↩ ↩2

  9. FCA Handbook, COBS 9 -- Suitability (including basic advice). https://handbook.fca.org.uk/handbook/COBS/9.pdf ↩

  10. FCA Handbook, PRIN 2A.3 -- Products and services outcome. https://handbook.fca.org.uk/handbook/PRIN/2A/3.html ↩

  11. FCA, Ongoing financial advice services multi-firm review (February 2025). https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services ↩ ↩2

  12. Finance Act 2025 (c. 8), ss.44-46 and Schedule 13 (residence-based IHT provisions). https://www.legislation.gov.uk/ukpga/2025/8/part/2/chapter/4 ↩

  13. FCA, Assessing Suitability Review. https://www.fca.org.uk/publications/multi-firm-reviews/assessing-suitability-review ↩

  14. FCA, Investment Advice Assessment Tool (IAAT), updated June 2025. https://www.fca.org.uk/firms/investment-advice-assessment-tool-iaat ↩

  15. FCA Handbook, PRIN 2A.4 -- Price and value outcome. https://handbook.fca.org.uk/handbook/PRIN/2A/4.html ↩ ↩2

  16. FCA, Consumer Duty: Findings from review of fair value frameworks (December 2025). https://www.fca.org.uk/publications/good-and-poor-practice/consumer-duty-findings-our-review-fair-value-frameworks ↩ ↩2

  17. HM Government, Autumn Budget 2024 -- Pension death benefits taxation from April 2027. https://www.gov.uk/government/publications/autumn-budget-2024 ↩

  18. FCA, Delivering good outcomes for customers in vulnerable circumstances -- Financial Lives data (2025). https://www.fca.org.uk/publications/good-and-poor-practice/delivering-vulnerable-customers ↩ ↩2

  19. FCA Handbook, PRIN 2A.6 -- Consumer support outcome. https://handbook.fca.org.uk/handbook/PRIN/2A/6.html ↩

  20. FCA, Retail banks' treatment of customers in vulnerable circumstances multi-firm review. https://www.fca.org.uk/publications/multi-firm-reviews/retail-banks-treatment-customers-vulnerable-circumstances-multi-firm-review ↩ ↩2

  21. FCA, Consumer Duty Board Reports: good practice and areas for improvement. https://www.fca.org.uk/publications/good-and-poor-practice/consumer-duty-board-reports-good-practice-and-areas-improvement ↩ ↩2

  22. FCA, Consumer Duty focus areas for 2025/26. https://www.fca.org.uk/publications/corporate-documents/consumer-duty-focus-areas ↩

  23. FCA Policy Statement PS25/22: Consumer pensions and investment decisions -- rules for targeted support. https://www.fca.org.uk/publications/policy-statements/ps25-22-consumer-pensions-investment-decisions-rules-targeted-support ↩

  24. FCA Consultation Paper CP25/36: Client categorisation and conflicts of interest. https://www.fca.org.uk/publications/consultation-papers/cp25-36-client-categorisation-conflicts-interest ↩

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