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Consumer Duty Training Gap Check. Ten Questions, Two Minutes.

Test your Consumer Duty training against what the FCA has said in its rules, guidance and reviews. Get a score out of 20, the gaps to close and what to do about each, with a source for every point.

Based on PRIN 2A, FG22/5, FG21/1 and FCA reviews up to July 2026. Nothing you enter leaves your browser.

Answer for the training your firm runs today. "Partly" means it is true for some roles or some of the time.

1Do you know which staff are in scope, and are all of them trained?
2Does your training cover the Duty itself: Principle 12, the three cross-cutting rules and the four outcomes?
3Does it explain Conduct Rule 6 and what it means in each person's job?
4Does each role get its own path, such as board, frontline, product, marketing and complaints?
5Does every path cover vulnerability, including for product and design staff?
6Is the training built around your own products, customers and journeys?
7Do assessments test judgement with realistic scenarios, rather than definitions?
8Can you report training results by role and team, including remedial training, for your board report?
9Do you compare training data with quality checks, complaints and vulnerability data?
10Do you update training when products, processes or FCA findings change?
THE RULES

Is Consumer Duty Training Mandatory?

There is no rule headed "Consumer Duty training", but three parts of the FCA's framework make it hard to comply without it.

The FCA's expectation

PS22/9 says the training firms give staff should enable them to understand their obligations under the Duty and the individual conduct rules. Read PS22/9.

Conduct Rule 6

"You must act to deliver good outcomes for retail customers." Section 64B of FSMA says the steps firms take on the conduct rules include suitable training. COCON 2.1.

Competence

SYSC 5.1 requires firms to employ people with the skills, knowledge and expertise their responsibilities need. SYSC 5.1.

ROLE BY ROLE

Who Needs What

A shared foundation for everyone, then content for each group. Vulnerability belongs in every row.

GroupWhat their training should focus on
Board and senior managersReading outcome data, challenging the annual board report, culture and incentives
Frontline and customer serviceComplex conversations, spotting vulnerability, consumer support, avoiding sludge
Product and designProduct governance, target markets, fair value, the needs of vulnerable customers
Marketing and communicationsConsumer understanding, testing communications, clear pricing information
Complaints, risk and complianceOutcome monitoring, root cause analysis, acting on what the data shows
WHAT THE FCA HAS FOUND

The Reviews Behind the Ten Questions

  • December 2024Good board reports included the proportion of staff who had completed training on Duty outcomes, including vulnerability. Board reports review
  • March 2025Staff need the skills to take account of customers in vulnerable circumstances, including product and service design staff, where firms had made little progress. Vulnerability review
  • December 2025PS25/21 removed the 15-hour CPD minimum for insurance and protection staff, but not the overall competence and training expectation. PS25/21
  • July 2026Culture described and supported by training, but not reflected in behaviour or incentives. Outcomes monitoring review
  • Q1 2027The FCA expects to publish its policy statement on the Duty's scope and proportionality after consulting in CP26/23. CP26/23
FAQ

Consumer Duty Training: Common Questions

Is Consumer Duty training mandatory?

There is no standalone rule headed Consumer Duty training, but in practice you cannot comply without it. PS22/9 says the training firms give staff should enable them to understand their obligations under the Duty and the individual conduct rules, section 64B of FSMA expects suitable training on the conduct rules, and SYSC 5.1 requires staff to have the skills, knowledge and expertise their roles need.

Who needs Consumer Duty training?

Almost everyone in a firm that serves retail customers. The FCA's guidance says the individual conduct rules apply to almost all employees except ancillary staff, and boards should make sure people throughout the firm, including control and support functions, understand their role in delivering the Duty.

How often should Consumer Duty training be refreshed?

The FCA does not set a frequency. Update training when products, processes or FCA findings change, and many firms review their programme alongside the annual board report.

Is a completion rate enough evidence for the board report?

No. FG22/5 points to training and competence records, including remedial action, and the FCA's July 2026 review criticised training that is not reflected in behaviour. Report results by role and team and set them next to outcome data such as quality checks and complaints.

Does Capytech sell ready-made Consumer Duty courses?

No. We build Consumer Duty training around your own products, customers and procedures, with role-based scenarios and LMS reporting by role and team. Updates go live within 48 hours.

Is the Duty's scope changing?

The FCA consulted on the Duty's scope and proportionality in CP26/23 and expects to publish a policy statement and any new rules in the first quarter of 2027. None of the proposals reduce what it expects from training for retail-facing staff.

Read our full guide to Consumer Duty training and what the FCA expects, or download the 10 checks as a PDF.

Training Built Around Your Products and Customers

We build Consumer Duty training from your own products, customers and procedures, with role-based scenarios, assessments that test judgement and LMS reporting by role and team for your board report.

No charge, no obligation.

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