Know your place in the Consumer Duty distribution chain!

The FCA published Consultation Paper CP26/23 on 29 June 2026, proposing targeted changes to how the Consumer Duty applies across scope and proportionality. The consultation closes on 18 September 2026, with a policy statement and final rules expected in Q1 2027.

The most reported change removes non-UK customer business from the Duty's scope entirely. The change that matters more for firms sitting inside a UK distribution chain is a new reliance framework, replacing the unclear co-manufacturing concept with defined principal and secondary manufacturer roles, and confirming firms need not police each other's compliance across the chain.

Most of the commentary on CP26/23 has led with the non-UK exclusion. For platforms, DFMs and product manufacturers actually sitting inside UK distribution chains, the reliance question is the one that was being asked for. It answers a genuine ambiguity that has sat unresolved since the Duty came in, who owns responsibility for an outcome when several regulated firms touch the same product on its way to a retail customer.

What this means in practice.

Reclassifying a product arrangement from co-manufacturer to principal or secondary manufacturer, or leaning on the new reliance right to reduce your own due diligence, both create a record of a judgement call. Those records are being created at the same time as six live FCA Consumer Duty investigations, disclosed in January 2026, several of them concerning fair value specifically. A record made at the point a decision is taken reads as governance. A record built later reads as justification.

We are not a law firm, and nothing here is legal advice. Our focus is on firms working out what their actual role is inside a distribution chain, and what that role should mean for their governance once the final rules land. We help platforms, DFMs and product manufacturers map their position across manufacturer and reliance arrangements, build the proportionate governance and documentation a supervisor would expect to see, and adjust board reporting to match the new proportionality guidance without losing real oversight.

If you want help working out where your firm actually sits under CP26/23, rather than where the headlines suggest, get in touch with your usual Trescore contact and we will talk it through before the 18 September deadline.

This is general information rather than legal, regulatory or tax advice, and reflects our reading of CP26/23 while the consultation remains open. Please take specific advice before relying on any of this for a decision that affects your firm.