The FCA requires all firms that distribute retail products to train relevant staff on Consumer Duty. Training must cover the Consumer Principle, the three cross-cutting rules and the four outcomes. The FCA’s 2026 supervisory stance requires role-specific training that shows staff how the Duty applies to their own decisions, and completion records alone are no longer sufficient.
The FCA’s Consumer Duty supervisory focus has moved on. Implementation is now assumed. In 2026 the question a supervisor asks is different: are you embedding the Duty in everyday decisions, monitoring whether customers actually receive good outcomes, and is your training keeping pace with that ambition? Completion records alone no longer answer it.
This guide sets out what the FCA expects Consumer Duty training to cover, who must complete it, and how to evidence it as the regulator’s stance shifts from ‘implemented’ to ‘embedded and evidenced’. It explains what the FCA expects; it is not legal advice. If you want practical guidance on structuring training across roles, see our companion piece on training your whole firm for Consumer Duty.
What does the FCA say about Consumer Duty training?
The FCA does not prescribe a fixed training curriculum but requires firms to embed the Consumer Duty in governance, culture and training. In 2026 its supervisory stance has shifted from whether the Duty has been implemented to whether it is embedded, monitored and evidenced in staff behaviour and decisions.
The FCA does not prescribe a fixed Consumer Duty training curriculum, but it is explicit that firms must ensure all relevant staff understand their obligations under the Duty. Its Consumer Duty Policy Statement (PS22/9) makes clear that firms should embed the Duty in their governance, culture and training, and not bolt it on as a one-off module.
The FCA’s multi-firm reviews in 2024 and 2025 found a recurring weakness: many firms had implemented Consumer Duty at a high level but lacked role-specific training that showed staff how the Duty applied to their own decisions. In 2026 the supervisory stance follows from that finding: training completion alone is insufficient. What matters is whether staff understand the outcomes they are expected to deliver, and whether the firm can show it.
Who must complete Consumer Duty training?
All staff at FCA-regulated firms that manufacture or distribute retail products must complete Consumer Duty training. The obligation is firm-wide but not identical for everyone: product and pricing teams, marketing, customer-facing staff, back office and senior managers all have distinct Consumer Duty responsibilities.
The Duty applies to all firms that manufacture or distribute products and services to retail customers, so the training obligation is firm-wide, though it is not identical for everyone.
- As a minimum, all staff should understand the Consumer Principle, the three cross-cutting rules and the four outcomes.
- Role-specific training layers depth onto that baseline by function: product, pricing, marketing, customer-facing, operations and senior management. Our companion guide on training your whole firm for Consumer Duty breaks this down role by role.
- Senior managers carry a specific accountability under the Duty to ensure the firm monitors customer outcomes and acts when they fall short. Their training should reflect that responsibility, not just the general principles.
What must Consumer Duty training cover?
Consumer Duty training must cover the Consumer Principle, the three cross-cutting rules (act in good faith, avoid foreseeable harm, support customers’ financial objectives) and the four outcomes: products and services, price and value, consumer understanding, and consumer support. Content must be role-specific, so product teams need depth on fair value while customer-facing staff need vulnerability and support training.
Effective training is structured around the cross-cutting rules and the four outcomes.
Cross-cutting rules. Every member of staff must understand the obligation to act in good faith, avoid foreseeable harm, and support customers in pursuing their financial objectives.
1. Products and services. Staff involved in product design, distribution or review must understand target-market definitions, what counts as a good outcome for that market, and how to spot products that are not delivering for customers.
2. Price and value. Pricing and product teams must understand the fair value requirement: the duty to assess and evidence that the price is reasonable relative to the benefit customers receive.
3. Consumer understanding. Marketing, communications and customer-facing teams must understand how to test whether communications are properly understood, not merely legally compliant, and how to identify ‘sludge’: friction that makes it hard for customers to act in their own interest.
4. Consumer support. Customer service, complaints and operations teams must understand how to provide support that lets customers realise the benefits of products and make informed decisions. This is where vulnerable-customer awareness is critical.
For the outcomes that depend most on front-line judgement, pair core training with our vulnerable customers training and complaints handling training, and consider conduct risk training for teams whose decisions most affect outcomes.
What has changed in the FCA’s Consumer Duty supervisory stance in 2026?
The FCA’s 2026 supervisory stance requires firms to move beyond implementation and evidence that the Duty is embedded in everyday decisions. Completion records alone no longer satisfy supervisors; firms must show role-specific training, link training to outcomes-monitoring data, and include a training review in the annual Consumer Duty board report.
The FCA’s 2025 communications to firms made the direction of travel clear: completion records alone do not demonstrate compliance. The questions now are whether training has changed behaviour, and whether the firm can monitor that.
What good looks like in 2026:
- Training tied to outcomes monitoring, so that when data shows a poor outcome, targeted training is one of the responses.
- Training linked to the annual Consumer Duty board report, so the governance review reflects what staff have actually been trained on.
- Role-specific training that can be evidenced against each of the four outcomes, rather than a single generic module for the whole firm.
The full supervisory expectations are set out on the FCA’s own Consumer Duty pages (fca.org.uk) and in its published review findings.
How should firms evidence Consumer Duty training to the FCA?
Firms must produce time-stamped completion records showing who was trained, in which role, and on which version of the course. Records must be role-attributed, demonstrating that product teams trained on fair value and customer-facing staff on vulnerability. A training review should also be included in the annual Consumer Duty board report.
To meet the embedding-and-evidencing standard, firms should be able to produce:
- Time-stamped completion records showing who completed training, in which role, and on which version of the course.
- Role-specific assignment records, demonstrating that product teams were trained on the products-and-services and price-and-value outcomes, not simply given a generic all-staff module.
- A training review as part of the annual Consumer Duty governance review.
- Monitoring evidence: where training was updated or re-assigned in response to a finding (for example, complaints data revealing a consumer-understanding issue), record the trigger and the re-assignment.
The CityREPORTS platform produces time-stamped, role-attributed completion records, and our guide to building a compliance training plan shows how to fit this into a wider, defensible programme.
Common questions about Consumer Duty training requirements
What must Consumer Duty training cover? It must cover the Consumer Principle, the three cross-cutting rules (acting in good faith, avoiding foreseeable harm, and supporting customers in achieving their financial objectives), and the four outcomes: products and services, price and value, consumer understanding, and consumer support. The FCA expects training to be role-specific, so product teams need depth on fair value, while customer-facing staff need to understand consumer vulnerability. A generic all-staff module meets the minimum but may not satisfy the expectation that staff understand the Duty as it applies to their own decisions.
Who needs Consumer Duty training? All staff at FCA-regulated firms that sell or distribute retail products. This includes product and pricing teams, marketing and communications, customer-facing staff, operations and back-office teams, and senior managers. Senior managers have a specific accountability to monitor customer outcomes and act when they fall short, and their training should reflect that responsibility.
How does the FCA expect firms to evidence Consumer Duty training? The FCA expects time-stamped completion records showing that the right people completed the right training. In 2026 its supervisory stance has shifted from whether the Duty has been implemented to whether it is embedded and monitored. Firms should be able to show role-specific completion, link training to their outcomes-monitoring data, and include a training review in their annual Consumer Duty board report.
How often should Consumer Duty training be refreshed? There is no fixed regulatory interval, but Consumer Duty training should be reviewed annually and updated whenever the FCA issues new guidance or multi-firm review findings. Firms should also re-assign training when their outcomes monitoring identifies a gap, or when staff move into a role that touches a different Consumer Duty outcome.
CityLearning’s Consumer Duty course is designed for all staff, with role-based assignment through CityREPORTS, so product teams, customer-facing staff and senior managers each see content relevant to their part in the Duty. The platform produces the time-stamped, role-attributed completion records the FCA expects. Request a demo to see how it maps to the four outcomes.