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The FCA has been busy. In the space of just a few months it's published proposals on redress, insurance rules, investment disclosures, and Consumer Duty scope. Four consultation papers, dealing with four very different corners of the Handbook. So if you've been trying to keep up with each one on its own, it's easy to lose track. Our compliance team has read all four in full, so you don't have to. Here's what each CP26 paper means individually, and what becomes clear when you look at them together.
CP26/9: Modernising redress
The FCA and FOS want firms identifying issues earlier, escalating faster, and taking greater ownership of customer outcomes, backed by a new complaint registration stage and tighter alignment between the two bodies.
Read the full CP26/9 blog for what this means for your complaints handling and MI data.
CP26/22: Simplifying insurance rules
Building on PS25/21, this paper narrows the scope of UK conduct rules for non-UK business, strips out low-value disclosures, and converts PII limits from euros to sterling. Most changes are optional, though two apply across the board.
Read the full CP26/22 blog for what this means for your disclosures and PII cover.
CP26/24: Simplifying investment disclosures
A single new Handbook chapter, COBS 6A, will replace the current patchwork of MiFID, IDD and non-MiFID cost disclosure rules, align pre-sale disclosures with the CCI regime, and ban firms from charging fees on cash while also keeping the interest.
Read the full CP26/24 blog for what this means for your systems and cost disclosure documents.
CP26/23: Consumer Duty scope and proportionality
Following the FCA's 2025 Mansion House commitment, this paper clarifies where the Duty applies and where it doesn't, limiting territorial scope to UK-resident retail customers and introducing clearer distribution chain categories. It's proportionality, not deregulation.
Read the full CP26/23 blog for what this means for your distribution chain mapping and board reporting.
Read individually, these are four papers doing four different jobs.
But read together, a clearer picture emerges.
Across redress, insurance, investment disclosures and Consumer Duty scope, the FCA is pushing the same underlying idea: strip out duplication and prescription where it doesn't serve the customer, and sharpen focus on the areas where firms can influence outcomes.
None of this is deregulation for its own sake. It's the regulator asking firms to spend less time on box-ticking and more time on judgement calls that protect end customers - whether that's spotting a complaint before it's raised, working out whether a customer disclosure earns its place, or deciding where the Duty applies.
And none of these benefits land automatically, so every paper does say some version of this: firms need to review, decide, and adopt the changes, not wait for them to arrive.
In short:
• Map your live consultation deadlines:
CP26/24 closes 21 August 2026
CP26/22 closes 4 September 2026
CP26/23 closes 18 September 2026
• Audit your disclosure documents against all three simplification papers at once. Insurance, investment cost, and Consumer Duty overlap more than you'd think
• Check your MI data and governance are strong enough to support earlier issue identification, a theme that runs through redress and Duty proportionality
• Review any non-UK business against the new territorial scope tests in both CP26/22 and CP26/23
• Consider whether your firm should respond to any of the live consultations directly
In practice, this could mean running one joined-up review, not four separate projects.
A lot of the groundwork (clean data, clear governance, sensible disclosure documents) serves more than one paper at a time.
The FCA's message across all four papers is consistent: firms need to concentrate on proportionality, clarity, and customer outcomes over ticking boxes.
Firms that treat all four as one connected exercise, rather than four separate compliance headaches, will get ahead faster and with less doing the same work twice (Thrice? More?).
Need a hand?
As always, our expert compliance team are here to help. If you need help with any part of the FCA’s recent papers, book a call now. We love to chat!
Maddie is compliance manager at Verve, with extensive experience and a passion for solving compliance challenges (and minimising frustration) for firms.
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