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What the FCA's Consumer Duty Simplification Means for Insurance Brokers, and What Hasn't Changed

Last checked 11 October 2026 against the sources below

The FCA is cutting complexity around Consumer Duty, not the Duty itself. Firms still need to show good customer outcomes, and simpler rules make that evidence matter more.

What the FCA Is Doing

Since 2025 the FCA has been reviewing its requirements on firms following the introduction of the Consumer Duty. It keeps a running update on its website, most recently updated in October 2026. Its stated priorities are more flexibility, more predictability and improved efficiency, which it describes as reducing the time, cost and complexity involved in meeting its expectations, while ensuring good customer outcomes.

That last part is the key. The FCA is simplifying how firms meet its expectations. It is not lowering the standard of outcomes customers should receive.

What Is Being Simplified for Insurance

• Insurance rules. In December 2025 the FCA published final rules to simplify requirements for insurance firms, intermediaries and funeral plan providers, including simpler SME thresholds.
• Co-manufacturing. Final rules allow some firms that manufacture insurance products together to appoint a single lead firm under PROD 4.2.
• Distribution chains. The FCA has consulted on making it clearer when and how firms can rely on each other when they work together in distribution chains. Final rules and guidance are due in the first quarter of 2027.
• Non-UK customers. The FCA has consulted on removing business with non-UK consumers from the scope of the Duty.
• Older guidance. More than 90 historic Dear CEO and portfolio letters and more than 100 multi-firm and thematic reports have been retired.

What Hasn't Changed

• The Consumer Duty itself, and the 4 outcomes: Products & Services, Price & Value, Consumer Understanding and Consumer Support.
• The expectation that firms monitor outcomes and report on them to their board at least once a year.
• The guidance on vulnerable customers, FG21/1. The FCA says it has no immediate plans to update it, although it is still considering whether that would help.
• Complaints handling under DISP, including the 8-week deadline for a final response.

The FCA has also decided not to carry out broader reviews of its product governance, client assets and training and competence rules for now.

The Complaints Return Is Part of This Work

The FCA lists its complaints reporting review as complete. That review produced PS25/19, which replaces 5 complaints returns with one. The first reporting period runs from 1 January to 30 June 2027, and the new return asks firms to report complaints from customers identified as vulnerable, and complaints that relate to a failure to consider or respond to a customer's vulnerability.

So while some requirements are getting lighter, the data firms need about complaints and vulnerability is becoming more specific.

The FCA Wants Firms to Use Technology

Among its priorities, the FCA says it wants more flexibility by enabling firms to innovate and take advantage of technology, and to tailor approaches to customers' circumstances, particularly those with characteristics of vulnerability. For a small broker, that is a clear signal: technology that helps you spot and support vulnerable customers, and evidence what you did, sits squarely within what the FCA is trying to encourage.

Simpler Rules Still Need Evidence

Fewer and clearer rules do not mean less proof. When requirements are less prescriptive, a firm has more room to choose how it meets them, and more responsibility to show that its choices deliver good outcomes. A board signing off its annual Consumer Duty report still needs data behind every conclusion. A principal firm still answers for every appointed representative. And from January 2027, every complaint from a vulnerable customer needs to be recorded so it can be reported.

What This Means for Brokers and AR Principal Firms

• Expect less paperwork in some areas, not less scrutiny of outcomes.
• Keep recording complaints, vulnerable customers and the Consumer Duty outcome each customer contact relates to.
• If you are an AR principal or work in a distribution chain, watch for the final distribution chain rules in 2027, which may change how you share and rely on information.
• Make sure your complaints records are ready for the new return from 1 January 2027.

How Omniron Helps

Omniron's Compliance Autopilot reads every customer email, flags complaints using the FCA's DISP definition and signs of vulnerability using the 4 FG21/1 drivers, starts the 8-week deadline and links each contact to the Consumer Duty outcome it affects. Your team confirms each flag, and every decision is recorded. The result is the evidence the FCA still expects, built as the work happens, with less time and cost for your team.