Consumer Duty in investment and wealth management is now less about implementation documentation and more about whether firms can demonstrate the outcomes customers actually receive. The FCA's March 2026 Consumer Investments Regulatory Priorities tells advisers and wealth managers to provide products and services that meet consumer needs, demonstrate fair value, communicate clearly and monitor outcomes, including for customers in vulnerable circumstances.
That expectation sits alongside detailed conduct rules such as COBS suitability and product-specific obligations. Consumer Duty does not replace those requirements. It requires firms to look across the complete relationship and ask whether the service, price, communication and support are producing good outcomes in practice.
For investment advisers and wealth managers, the difficult areas are often recurring fees, ongoing services, portfolio and model distribution chains, cash treatment, vulnerable clients and the quality of management information. A strong Duty framework connects those issues rather than treating each of the four outcomes as a separate annual compliance exercise.
Start with the service the client is actually buying
The products and services outcome should begin with the proposition the firm actually provides. A one-off advice service, an ongoing advice relationship, discretionary portfolio management and an execution or platform service create different customer expectations, benefits and risks.
The target market should therefore be precise enough to inform design. A discretionary service built for experienced high-net-worth clients may not be appropriate for a customer who needs simple investment support, while a standardised model portfolio proposition can create different risks where client circumstances fall outside the assumptions used in its design.
Firms should also distinguish the regulated service from the underlying investment product. An adviser can recommend a suitable product but still deliver a poor service outcome if the customer pays for reviews that are not provided, cannot transfer promptly or receives communications that do not explain the ongoing relationship.
The FCA's 2026 Consumer Investments priorities emphasise accountability across distribution chains. That matters where advisers, platforms, discretionary managers, Model Portfolio Service providers and product manufacturers each influence the customer outcome. A firm should understand its own role and the information it needs from other participants rather than assume another regulated firm owns the whole result.
Fair value should assess the complete price against the service delivered
The price and value outcome is particularly important in wealth management because a customer can pay several layers of cost. Advice fees, portfolio management fees, platform charges, fund charges, transaction costs and other costs can combine into a material total price even where each component appears reasonable in isolation.
The fair value assessment should therefore consider the service customers actually receive and the benefits that justify the firm's charge. For advisers, that can include financial planning, periodic suitability work, ongoing access and implementation support. For discretionary managers, it can include portfolio construction, risk management, reporting, service and investment management expertise.
Benchmarking can provide context, but it is not the conclusion. The FCA's current price and value material expects firms to assess the relationship between price and benefits rather than rely only on the fact that competitors charge similar amounts. The assessment should also consider whether particular groups receive materially different value.
Portfolio size can be important. A minimum or percentage fee can create a different value outcome for smaller clients than for larger clients receiving broadly the same service. The FCA's 2026 wealth management survey also keeps fair value and treatment of client cash in focus. Firms should be able to explain how charging structures operate across their actual client population rather than rely on one average-client example.
There is no universal rule that every fair value assessment must be repeated on the same annual timetable. Review should be proportionate to the product or service and should respond to material changes, emerging risks and evidence that value may have deteriorated.
Ongoing advice must be delivered where the customer pays for it
Ongoing advice remains a clear Consumer Duty control issue. The FCA's 2025 multi-firm review examined whether financial advisers were delivering ongoing services for which customers had paid and reinforced the importance of firms being able to evidence the service promised.
The control should begin with the client agreement. The firm should be clear about what the ongoing service includes, how often contact or suitability review is expected, what happens if the client does not engage and when fees may need to stop or be refunded.
Management information should then show whether the service was actually delivered. A scheduled review invitation is not necessarily the same as delivery of the contracted service, particularly where the firm's own proposition promises a substantive suitability assessment or planning review.
Where clients repeatedly disengage, the firm should have a defined process rather than allow fees to continue indefinitely without challenge. The correct response depends on the contract, the regulatory requirements applying to the service and the customer's circumstances. The firm should be able to demonstrate why continued charging remains fair and what attempts were made to provide the service.
Suitability evidence should support the Duty, not sit beside it
For advised and discretionary business, suitability is one of the strongest sources of Consumer Duty evidence. COBS 9 and COBS 9A contain the detailed suitability regimes applying to different investment business, and firms should use the chapter that applies to the service rather than treat suitability as one generic rule.
The customer file should show why the recommendation or portfolio is appropriate for the client's objectives, financial situation, ability to bear losses and risk profile where those requirements apply. Consumer Duty adds the wider question of whether the advice process and ongoing service continue to produce an appropriate outcome.
A technically complete fact-find can still be weak if the reasoning is formulaic. The review should connect the customer's circumstances with asset allocation, product selection, liquidity, costs and material alternatives. Where circumstances change, the firm should be able to show how the service responds.
Quality assurance should therefore assess judgement, not only document presence. Repeated weaknesses in suitability reasoning should feed training, proposition design and compliance monitoring rather than remain isolated adviser findings.
Consumer understanding should make risks, rewards and costs usable
The FCA's 2026 Consumer Investments priorities expressly expects clear, jargon-free information about investment benefits, risks and costs before consumers make decisions. This is particularly important in wealth management, where technical language can become normal inside the firm but remain difficult for customers.
Consumer understanding should be tested across the journey. Initial propositions, suitability reports, discretionary mandates, cost disclosures, investment reports and communications about material changes can each affect the customer's ability to understand what they are buying and how it is performing.
The firm should not assume that regulatory disclosure equals understanding. A document can contain every required field and still be difficult to use. Customer testing, complaints, recurring questions, call reviews and digital behaviour can provide evidence of where communications are not working.
Cost communication deserves particular attention because customers may see several fee components on different documents. Firms should consider whether the overall cost is understandable without requiring the client to reconstruct it from multiple sources.
The Consumer Composite Investments regime and targeted support reforms also change parts of the investment communications landscape in 2026. Firms should apply the requirements relevant to their service and avoid importing new regimes into advice propositions where they do not apply.
Support and vulnerability need to work through the whole relationship
Investment clients can become vulnerable long after onboarding. Bereavement, cognitive decline, serious illness, relationship breakdown or a sudden loss of financial resilience can affect the way the customer needs to interact with the firm.
The FCA's Consumer Investments priorities specifically refers to good service and characteristics of vulnerability such as bereavement. Firms should therefore consider how support needs are identified, recorded and carried across advice, portfolio management, operations and complaints.
A vulnerability flag should have a practical effect where necessary. The client may need more time, another communication channel, support from an authorised third party or clearer explanation before a significant investment decision. The firm should record enough information to deliver that support without collecting unnecessary sensitive detail.
Transfer and service delays also matter. A client trying to move investments should not face unreasonable barriers simply because retention is commercially preferable. Outcome monitoring should therefore consider transfer times, repeated contacts and complaints rather than focus only on investment performance.
Model portfolios and distribution chains need shared evidence
Model Portfolio Services can create complex accountability because the adviser may select the service while a discretionary manager constructs and changes the underlying model and a platform executes the transactions. Consumer Duty does not allow each participant to assume that another firm has assessed the complete customer outcome.
The adviser should understand why the MPS is appropriate for the clients to whom it is recommended, including risk, cost, investment approach and service characteristics. The MPS provider should understand its own target market, value and distribution arrangements and provide information needed by distributors to meet their obligations.
Changes to a model can create downstream effects. If risk, cost, asset mix or strategy changes materially, distributors may need enough information to assess whether the service remains appropriate for their clients.
The FCA's 2026 priorities state that it is progressing its review of MPS firms. Wealth and advice firms should therefore be able to demonstrate how information moves across the chain and how responsibility is allocated in practice.
Outcomes monitoring should identify the weakest result, not the average
The FCA's current Consumer Duty approach expects firms to assess, test, understand and evidence outcomes. A wealth manager's dashboard should therefore do more than show that average client satisfaction is high or investment performance is positive.
Useful evidence can include advice QA, ongoing-service delivery, fair value, transfers, complaints, vulnerable customer outcomes, client cash, service levels and product or portfolio exceptions. The exact measures depend on the firm's proposition.
Segmentation matters because overall averages can conceal poor results. Smaller portfolios may experience different value, one adviser may have repeated suitability findings, or one model may generate materially more complaints or transfer problems.
Management should define what good looks like and what action follows when evidence falls outside tolerance. Data without an intervention framework can become reporting rather than monitoring.
The annual governing-body Consumer Duty assessment should summarise and challenge this evidence. It should not be the first place the firm discovers a material customer outcome problem.
Governance should connect Duty evidence with the wider control framework
The FCA's 2026 Consumer Investments priorities places strong governance, risk systems and responsible innovation alongside good consumer outcomes. Wealth firms should therefore integrate Duty evidence with compliance monitoring, product governance, financial crime, operational resilience and senior management oversight.
The August 2026 wealth management survey provides a further current benchmark for discretionary wealth managers. It highlights a large and evolving sector and reinforces the FCA's interest in governance, fair value, financial crime, support and responsible use of technology.
Senior management should understand where the firm's evidence is weakest. A board pack containing only green ratings can be less useful than one that identifies a genuine service or value issue, explains the customer population affected and records what management is changing.
The practical standard is not perfection. It is a control framework capable of detecting poor outcomes and responding before they become systemic.
How Regulatory Counsel can support
Regulatory Counsel supports investment advisers, wealth managers and principal firms with Consumer Duty reviews, fair value, ongoing-service testing, suitability QA, vulnerable customer frameworks, outcomes monitoring and remediation.
We can review the complete Duty framework or focus on a specific service, charging model, MPS distribution chain or customer population.
Our work with investment and wealth firms combines Consumer Duty review with ongoing compliance support and independent compliance audit where the board needs assurance.
Speak to Regulatory Counsel to discuss Consumer Duty support for an investment or wealth firm.
Frequently Asked Questions
No. Consumer Duty operates alongside COBS and other applicable conduct requirements. Firms still need to comply with the detailed suitability regime applying to their investment service.
Yes where the relevant retail service falls within the price and value outcome. Investment performance can be relevant to benefits, but value should consider the overall relationship between price, service and benefits rather than performance alone.
There is no universal annual reassessment rule applying identically to every product or service. Review should be proportionate and should respond to material change, emerging risks and relevant outcome evidence.
Firms should be able to evidence whether the contracted service was delivered, identify clients who did not receive it, manage disengaged clients and consider the charging or remediation consequences where appropriate.
Yes. We can review the underlying evidence, fair value, service delivery, outcome segmentation and the governing-body assessment before or after board approval.