There is no FCA rule headed “Consumer Duty training”, but the FCA clearly expects it. Its policy statement says the training firms give staff “should enable them to understand their obligations under the Duty and the individual conduct rules”, and the law already requires suitable training on the conduct rules. Since 2024 the FCA’s reviews have gone further, criticising training that is described in policies but not reflected in how staff behave. Consumer Duty training therefore has to change decisions, and you need evidence that it has.
This guide covers what the FCA has said about training under the Duty, who needs what, how to evidence it for your board, and what is changing in 2026.
The Consumer Duty in brief
The Consumer Duty is Principle 12 of the FCA’s Principles for Businesses: “A firm must act to deliver good outcomes for retail customers.” The detailed rules sit in PRIN 2A and have three parts:
- Three cross-cutting rules: act in good faith towards retail customers, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives.
- Four outcomes: products and services, price and value, consumer understanding, and consumer support.
- Governance: at least once a year your board or equivalent must review and approve a report on whether the firm is delivering good outcomes.
The FCA published the rules in PS22/9 in July 2022. They applied from 31 July 2023 for products open to sale or renewal, and from 31 July 2024 for closed products.
Is Consumer Duty training mandatory?
Not as a standalone rule, but in practice you cannot comply without it. Three things make that clear.
- The FCA’s own expectation. PS22/9 says: “The training that firms give to their staff should enable them to understand their obligations under the Duty and the individual conduct rules.”
- The conduct rules. Individual Conduct Rule 6 says “You must act to deliver good outcomes for retail customers.” Under section 64B of FSMA, the steps a firm must take so that staff understand the conduct rules “include, in particular, the provision of suitable training.” The FCA’s guidance (FG22/5) notes the conduct rules apply to almost all employees except ancillary staff.
- Competence. SYSC 5.1.1R requires firms to employ people with the skills, knowledge and expertise their responsibilities need.
Payment and e-money firms sit outside the Senior Managers and Certification Regime, but FG22/5 says they must still make sure their staff act in line with the Duty.
Who needs Consumer Duty training, and what each group needs
One generic module for everyone is the most common weakness. The FCA’s guidance asks boards how they make sure individuals, “including those in control and support functions”, understand their role in delivering the Duty. That means different content for different roles.
| Group | What their training should focus on |
|---|---|
| Board and senior managers | Reading outcome data, challenging the annual board report, culture and incentives |
| Frontline and customer service | Complex conversations, spotting vulnerability, consumer support, avoiding sludge |
| Product and design | Product governance, target markets, fair value, the needs of vulnerable customers |
| Marketing and communications | Consumer understanding, testing communications, clear pricing information |
| Complaints, risk and compliance | Outcome monitoring, root cause analysis, acting on what the data shows |
Vulnerability belongs in every group. PRIN 2A expects firms to help frontline staff identify information that could indicate vulnerability, and the FCA’s vulnerability guidance (FG21/1) says “All relevant staff should understand how their role affects the fair treatment of vulnerable consumers.” In March 2025 the FCA reported a lack of vulnerability training for product and design staff in particular.
What the FCA has found so far
The FCA has published a series of good and poor practice reviews since the Duty came in. The points on training are consistent:
- February 2024, implementation review: some firms did “not train staff well enough in terms of having complex conversations with customers.”
- December 2024, board reports: good reports included data on the number or proportion of staff who had completed training on Duty-related outcomes. An update for smaller firms in February 2026 suggested keeping clear records of training and noted that scenario-based training can help.
- March 2025, consumer support: “Some firms failed to evidence appropriate training and other measures that enable their staff to understand their role in delivering good outcomes.”
- March 2025, vulnerable customers: monitoring staff training records on their own “may not give a full understanding of the outcomes”.
- July 2026, outcomes monitoring: one section is headed “Culture described and supported by training, but not reflected in behaviour or incentives”. The FCA found training often “amounts to describing a culture at a high level”, with no evidence of how it affects decisions.
- September 2026, payments firms: some firms “had policies and training in place but were not always able to show how these were working in practice.”
The message is clear. A course that explains the Duty and records a completion is no longer enough. The FCA wants to see that people make different decisions as a result.
To see how your own programme measures up against these findings, take our free Consumer Duty training gap check: ten questions, a score out of 20 and the gaps to close.
What good Consumer Duty training looks like
From the reviews above, and from building compliance training for regulated organisations, these are the features that hold up:
- Built around your products and customers. Use your own products, scripts, journeys and customer types. Generic examples teach the theory and leave staff to work out the application on a live call.
- Scenario-based. Put people in the decisions they face: a customer who mentions a bereavement, a renewal price that looks out of line, a complaint that points to a product problem. Let them choose, see the consequence and try again.
- Role-based paths. Shared foundations for everyone, then content for each group in the table above.
- Assessment that tests judgement. Questions about what to do in a situation, not definitions. Our guide to setting an e-learning pass mark covers how to set the bar.
- Short and current. Modules people can finish in a sitting, updated when products, processes or FCA findings change.
- Connected to culture. Training sits alongside incentives, quality assurance and management conversations. On its own it will not shift behaviour, which is exactly what the FCA found.
Free checklist: Consumer Duty training in 10 checks
A two-page PDF to test your programme before your next board report: who needs training, what to cover and how to evidence it.
How to evidence training for your board report
FG22/5 lists “Training and competence records” as management information that can support the board’s assessment, including “remedial actions where staff knowledge or actions were found to be below expectations.” A useful training section in your board report covers:
- completion and assessment results by role and team, not one firm-wide percentage
- the scenarios or questions people found hardest, and what you changed as a result
- links to outcome data, such as call quality findings, complaints themes and vulnerability flags
- remedial training given where quality assurance found problems
- how the training was updated after product changes or new FCA publications
Your LMS should give you most of this directly. If it can only report completions, that is a gap worth closing before the next board report.
What is changing in 2026
A few changes affect how firms organise Duty training:
- The FCA no longer expects firms to have a board-level Consumer Duty champion, from 27 February 2025.
- In December 2025 (PS25/21) the FCA removed the mandatory 15-hour CPD minimum for general insurance and pure protection staff. It said this was “not intended as a relaxation of the overall competence and training expectation.”
- In June 2026 the FCA consulted in CP26/23 on clarifying the Duty’s scope, including for wholesale firms, distribution chains and business with non-UK customers. These are proposals, with a policy statement expected in 2027.
None of these reduce what the FCA expects from training for retail-facing staff.
How Capytech helps
We build FCA compliance e-learning around your own products, procedures and customers, with scenario-based modules for each role and assessments that test judgement. Reporting from the LMS gives you the training records your board report needs, by role and team.
Products and procedures change, so content has to keep up. With FastTrack, updates are unlimited and turned around within 48 hours, so training reflects how the firm works today. Courses can be delivered in English or any other language. See our financial services e-learning page for more.
Frequently asked questions
There is no standalone rule called Consumer Duty training. However, section 64B of FSMA requires suitable training on the conduct rules, including Conduct Rule 6, and the FCA’s policy statement says training should help staff understand their obligations under the Duty. In practice, firms need it to comply.
In firms under the Senior Managers and Certification Regime, the conduct rules apply to almost all employees except ancillary staff. That includes product, marketing, control and support staff as well as the front line. Payment and e-money firms are expected to make sure their staff act in line with the Duty too.
The FCA does not set a frequency. Many firms align refreshers with the annual board report cycle, and update training whenever products, procedures or FCA findings change.
No. The FCA has criticised firms whose training was not reflected in behaviour, and said training records alone may not show outcomes. Combine completion and assessment data with quality assurance findings, complaints themes and the actions you took.
It can. The Duty covers firms that determine or materially influence outcomes for retail customers, even without a direct customer relationship. The FCA has consulted on clarifying the scope for wholesale firms and distribution chains, but those changes are still proposals.
Consumer Duty training your people will actually use
We build FCA compliance e-learning around your own products, customers and procedures, with the evidence your board report needs.