Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

17 QUICK LINKS FINTECH MIFID II/MIFIR OPEN FINANCE SUSTAINABLE FINANCE/ESG T+1 ASIA AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2025 UNITED KINGDOM Consumer Duty Requirements Review: Update On 30 September 2025, the Financial Conduct Authority (FCA) published a webpage detailing how it is streamlining its rules and reducing complexity for businesses following the introduction of the Consumer Duty. The webpage details the FCA’s: • Priorities for streamlining its regulatory requirements; • Wider work on the Consumer Duty; • Feedback on its requirements of firms; • Feedback on its regulatory approach; • Action plan; and • Future priorities. Link to the Webpage here In addition to the webpage, the FCA published details of its Consumer Duty focus areas for 2025 to 2026. The FCA details: • Its priority areas for 2025/26; • Plans for multi-firm projects to look at how the Duty is being embedded across sectors covering four cross-cutting projects: – Review of products and services outcome – How firms are designing products and services to meet customer needs, including those with characteristics of vulnerability. – Review of firms’ approaches to outcomes monitoring – How firms are responding to the FCA’s outcomes monitoring requirements. – Review of firms’ customer journey design – Looking at the design and delivery of firms’ customer journeys to ensure customers’ needs are met, with a particular focus on how firms apply friction throughout the journey. – Review of the consumer understanding outcome – How firms’ communications are helping consumers make informed decisions. • Plans to provide firms vulnerability, data sharing, and data protection expectations under the Consumer Duty; • Its priorities in supporting firms deliver good outcomes under the price and value outcome; and • Plans to undertake sector specific work including: – Assessing whether firms are meeting Consumer Duty expectations for retail customers investing in complex exchange traded products; – Sustainability disclosure requirements (SDR) and investment labels – although the FCA says this is currently paused while it works to finalise rules on extending SDR to portfolio management. Link to Focus Areas here