# FCA PS22/9 Consumer Duty: PS22/9: A new Consumer Duty — Feedback to CP21/36 and final rules (with FG22/5 guidance)

Source: https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty
Last updated: Oct 5, 2026

PS22/9, published by the FCA on 27 July 2022, introduced the Consumer Duty: a new Principle 12 ('A firm must act to deliver good outcomes for retail customers'), a new Handbook chapter PRIN 2A, and non-Handbook guidance in FG22/5. The rules came into force on 31 July 2023 for new and existing products open to sale or renewal and on 31 July 2024 for closed products. The Duty has three cross-cutting rules (act in good faith, avoid causing foreseeable harm, enable and support customers to pursue their financial objectives) and four outcomes (products and services, price and value, consumer understanding, consumer support). The Duty does not mention AI by name in PS22/9, but the FCA's April 2024 AI Update says firms using AI must consider their Consumer Duty obligations, and FG22/5 says algorithms that embed or amplify bias may not be good faith.

## At a glance

| Field | Value |
| --- | --- |
| Authority | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) |
| Type | Regulation |
| Status | In force |
| Published | Jul 27, 2022 |
| Effective | Jul 31, 2023 |
| Applies to | FCA-authorised firms in their retail market business, across the distribution chain, including banks, building societies, lenders, payment firms and insurers dealing with retail customers (including prospective customers). The Duty is technology-neutral: it applies equally to products, communications and support delivered or decided by AI. Firms not conducting retail market business remain under Principles 6 and 7. |
| Official text | https://www.fca.org.uk/publications/policy-statements/ps22-9-new-consumer-duty |

## Key points

- Principle 12 (PRIN 2.1.1R): 'A firm must act to deliver good outcomes for retail customers.' PRIN 2A.1.17G says it imposes a higher and more exacting standard than Principles 6 and 7 for retail market business.
- Cross-cutting rules: PRIN 2A.2.1R act in good faith; PRIN 2A.2.8R avoid causing foreseeable harm; PRIN 2A.2.14R enable and support retail customers to pursue their financial objectives.
- Products and services outcome (PRIN 2A.3): manufacturers must maintain, operate and review a product approval process before marketing or distribution (PRIN 2A.3.2R).
- Price and value outcome (PRIN 2A.4): manufacturers must ensure products provide fair value to customers in the target market and carry out and regularly review a value assessment (PRIN 2A.4.2R).
- Consumer understanding (PRIN 2A.5) and consumer support (PRIN 2A.6): communications must meet customers' information needs and be likely to be understood (PRIN 2A.5.3R); support must meet the needs of customers, including those with characteristics of vulnerability (PRIN 2A.6.2R).
- Governance and monitoring: Principle 12 must be reflected in strategy, governance and incentives (PRIN 2A.8.1R); the governing body must review an annual report on customer outcomes and confirm compliance (PRIN 2A.8.3R, 2A.8.4R); firms must regularly monitor outcomes (PRIN 2A.9.8R).
- AI link: FG22/5 paragraph 5.12 lists 'using algorithms, including machine learning or artificial intelligence' in ways that embed or amplify bias and lead to systematically worse outcomes for some groups as an example of not acting in good faith, unless the difference can be justified objectively.
- June 2026: the FCA's CP26/23 'Consumer Duty – scope and proportionality' proposes changes to the Duty's scope and presentation, including a new chapter PRIN 3A; its consultation closed on 18 September 2026. These are proposals, not rules.

## What changed for banks

PS22/9 moved FCA conduct supervision of retail firms from process-based rules towards outcome testing: firms must be able to evidence good outcomes, not just follow procedures. For banks using AI in credit decisions, pricing, chatbots or collections, the Duty supplies the FCA's main conduct lens: the same Principle 12 standards apply regardless of technology, so a model that produces systematically worse outcomes for a customer group, or a chatbot customers cannot understand, is a Duty issue. The Duty is therefore a main conduct rulebook the FCA points to for AI in UK retail banking.

## Use cases it governs

- [Customer-facing chatbots](https://www.bankingnewsai.com/ai-regulation/by-use-case#customer-chatbots)
- [Credit scoring & underwriting](https://www.bankingnewsai.com/ai-regulation/by-use-case#credit-underwriting)
- [Fair lending & discrimination](https://www.bankingnewsai.com/ai-regulation/by-use-case#fair-lending)
- [Model risk management](https://www.bankingnewsai.com/ai-regulation/by-use-case#model-risk)
- [AI governance (general)](https://www.bankingnewsai.com/ai-regulation/by-use-case#governance-general)
- [Fraud detection](https://www.bankingnewsai.com/ai-regulation/by-use-case#fraud)

## What does the FCA Consumer Duty require of banks, including when they use AI?

The FCA Consumer Duty, introduced by PS22/9 on 27 July 2022 and in force from 31 July 2023 (closed products 31 July 2024), requires a firm to 'act to deliver good outcomes for retail customers' (Principle 12) and sets detailed rules in PRIN 2A. Three cross-cutting rules require good faith (PRIN 2A.2.1R), avoidance of foreseeable harm (PRIN 2A.2.8R) and support for customers' financial objectives (PRIN 2A.2.14R), and four outcomes cover products and services, price and value, consumer understanding and consumer support. Firms must embed the Duty in governance, have the board review an annual outcomes report, and monitor the outcomes customers actually receive. The Duty is technology-neutral, so it applies to AI used in credit decisions, pricing, chatbots and collections; the FCA's AI Update says firms must consider their Consumer Duty obligations, and FG22/5 warns that AI embedding or amplifying bias may not be good faith.

| Rule | Authority | What it requires | Status | Source |
| --- | --- | --- | --- | --- |
| Principle 12 / PRIN 2.1.1R — Consumer Duty | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must act to deliver good outcomes for retail customers; PRIN 2A.1.17G describes this as a higher and more exacting standard than Principles 6 and 7. | In force since 31 Jul 2023 (closed products 31 Jul 2024) | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.2.1R — act in good faith | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must act in good faith towards retail customers; FG22/5 paragraph 5.12 gives AI or algorithms that embed or amplify bias as an example of conduct that may not be in good faith. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.2.8R — avoid foreseeable harm | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must avoid causing foreseeable harm to retail customers, by act or omission. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.2.14R — enable and support | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must enable and support retail customers to pursue their financial objectives. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.3.2R — product approval | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A manufacturer must maintain, operate and review a process for approving a product and significant adaptations before it is marketed or distributed. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.4.2R — fair value | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A manufacturer must ensure its products provide fair value to retail customers in the target market and carry out and regularly review a value assessment. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.5.3R — consumer understanding | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must support retail customer understanding so that its communications meet information needs and are likely to be understood. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.6.2R — consumer support | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must design and deliver support that meets the needs of retail customers, including those with characteristics of vulnerability. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.8.1R, 2A.8.3R, 2A.8.4R — governance | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | Principle 12 must be reflected in strategy, governance and incentives; the governing body must receive a report on monitoring results and, at least annually, review it and confirm whether the firm is complying. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |
| PRIN 2A.9.8R — monitoring outcomes | [UK (BoE / PRA / FCA)](https://www.bankingnewsai.com/ai-regulation/uk) | A firm must regularly monitor the outcomes customers receive from products, communications and customer support. | In force since 31 Jul 2023 | [FCA PS22/9 Consumer Duty](https://www.bankingnewsai.com/ai-regulation/documents/fca-ps22-9-consumer-duty) |

The Duty is the FCA's main tool for conduct risk from AI. The FCA's AI Update (April 2024) says its approach to consumer protection, including the Consumer Duty, is particularly relevant to fairness in firms' use of AI, and gives examples: an AI risk assessment can leave some customers better off than others and exclude some from the market, while an AI chatbot can help customers understand products. PS22/9 itself contains no AI-specific rules; the Duty's general rules apply to AI.

In practice the Duty is evidenced through outcomes data. The monitoring rule in PRIN 2A.9.8R and the board reporting in PRIN 2A.8.3R and 2A.8.4R mean a bank deploying a credit or pricing model needs outcome metrics broken down by customer group, including customers with characteristics of vulnerability, and board-level challenge of the results. This sits beside the PRA's model-risk expectations in SS1/23, which govern how models are built and validated, and beside data-protection rules on automated decisions.

The FCA is reviewing the Duty. In June 2026 it published CP26/23 on the Duty's scope and proportionality, proposing among other things a new PRIN 3A chapter for scope rules; consultation closed on 18 September 2026 and no final rules have been confirmed at the date of this entry. Rule references in this entry are those made by PS22/9; firms should check the live Handbook for later amendments.

### What this means in practice

- Treat every customer-facing model and chatbot as in scope of Principle 12: record the intended customer outcome, the target market and the evidence that outcomes are good.
- Test AI-driven credit, pricing and collections for systematically worse outcomes for groups of customers and document any objective justification, using FG22/5 paragraph 5.12 as the benchmark for good faith.
- Include customers with characteristics of vulnerability in outcome monitoring, because PRIN 2A.6.2R support and PRIN 2A.9.8R monitoring both require it.
- Put AI-related outcome evidence into the annual board report under PRIN 2A.8.3R and 2A.8.4R so the board can confirm Duty compliance.
- Track CP26/23 and the live Handbook for scope and presentation changes (PRIN 3A) before relying on rule numbers in policies.

## FAQ

### Does the FCA Consumer Duty apply to AI?

Yes. The Duty is technology-neutral and applies to any product, communication or support a firm delivers to retail customers, including through AI. In its AI Update the FCA says firms using AI should consider their Consumer Duty obligations, and FG22/5 gives AI or algorithms that embed or amplify bias as an example of conduct that may not be in good faith.

### When did the Consumer Duty come into force?

31 July 2023 for new and existing products and services open to sale or renewal, and 31 July 2024 for closed products and services. PS22/9 was published on 27 July 2022.

### Does the Consumer Duty apply to banks?

Yes, to FCA-authorised banks and other firms in their retail market business, across the distribution chain and including prospective retail customers. For business that is not retail market business, Principles 6 and 7 continue to apply.

### What are the three cross-cutting rules of the Consumer Duty?

PRIN 2A.2.1R requires firms to act in good faith towards retail customers, PRIN 2A.2.8R to avoid causing foreseeable harm, and PRIN 2A.2.14R to enable and support retail customers to pursue their financial objectives.

### Is the Consumer Duty being changed in 2026?

The FCA published consultation paper CP26/23 in June 2026 proposing changes to the Duty's scope and proportionality, including a new PRIN 3A chapter bringing together the scope provisions; the consultation closed on 18 September 2026. Until the FCA publishes final rules, PRIN 2A as made by PS22/9 (as since amended) remains the operative text.

## Related documents

- [Bailey: Frontier AI and the Question of Governance (Sep 2026)](https://www.bankingnewsai.com/ai-regulation/documents/boe-bailey-frontier-ai-governance-2026) — Frontier AI and the Question of Governance — Governor Andrew Bailey (Sep 30, 2026)
- [FCA multi-firm review: Frontier AI and cyber resilience (Sep 2026)](https://www.bankingnewsai.com/ai-regulation/documents/fca-frontier-ai-cyber-resilience-2026) — Frontier AI and Cyber Resilience (Sep 2, 2026)
- [HM Treasury Financial Services AI Adoption Plan (Jul 2026)](https://www.bankingnewsai.com/ai-regulation/documents/hmt-financial-services-ai-adoption-plan-2026) — Financial Services AI Adoption Plan (Jul 14, 2026)
- [2026 BoE/FCA AI survey](https://www.bankingnewsai.com/ai-regulation/documents/uk-ai-in-financial-services-survey-2026) — The Bank of England and FCA's 2026 AI Survey (Jun 5, 2026)
- [BoE/FCA/HMT joint statement on frontier AI and cyber resilience (May 2026)](https://www.bankingnewsai.com/ai-regulation/documents/uk-joint-statement-frontier-ai-cyber-resilience-2026) — The Bank, FCA and HM Treasury joint statement on Frontier AI models and cyber resilience (May 15, 2026)
- [BoE response to Treasury Committee AI inquiry (Apr 2026)](https://www.bankingnewsai.com/ai-regulation/documents/boe-pra-response-tsc-ai-inquiry-2026) — Response to TSC inquiry report on AI in financial services (Apr 1, 2026)
- [BoE/PRA plan for safe AI innovation (Apr 2026)](https://www.bankingnewsai.com/ai-regulation/documents/boe-pra-safe-ai-innovation-plan-letter-2026) — Letter from Sarah Breeden and Sam Woods to the Chancellor and Secretaries of State on enabling safe AI innovation (Apr 1, 2026)
- [DSIT/DBT strategic letters to regulators (Jan 2026)](https://www.bankingnewsai.com/ai-regulation/documents/gov-uk-dsit-dbt-safe-ai-innovation-letter-2026) — How will regulators enable safe AI-powered innovation: joint letter from DSIT Secretary of State and DBT Secretary of State (Jan 28, 2026)

Last reviewed Oct 5, 2026. Cite the official text (https://www.fca.org.uk/publications/policy-statements/ps22-9-new-consumer-duty) for the rule and this page for the summary and dates.

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