The Consumer Duty has three cross-cutting rules: act in good faith towards retail customers, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives. For an adviser firm, all three come down to one test: can you show, client by client, that what each person pays for is what they receive?
Most firms can describe their service. Fewer can prove it for every client on the book. The rules are written to find that gap.
Where the cross-cutting rules sit
The Consumer Duty sits in PRIN 2A of the FCA Handbook. At the top is the Consumer Principle: a firm must act to deliver good outcomes for retail customers. Beneath it are the three cross-cutting rules in PRIN 2A.2, in force since 31 July 2023. Beneath those are the four outcomes: products and services, price and value, consumer understanding and consumer support.
The cross-cutting rules apply to everything a firm does. They are the standard each outcome is judged against.
Rule one: act in good faith
PRIN 2A.2.1R says a firm must act in good faith towards retail customers. PRIN 2A.2.2R defines good faith as honesty, fair and open dealing, and acting consistently with the reasonable expectations of retail customers.
That last part is the one advisers should read twice. A client paying an ongoing advice fee reasonably expects an ongoing service. If the file shows the fee leaving the account every month and no review on record, the firm has a gap between what the client expects and what it delivered. Good intentions do not close it. Evidence does.
Rule two: avoid causing foreseeable harm
PRIN 2A.2.8R says a firm must avoid causing foreseeable harm to retail customers. PRIN 2A.2.9R adds that harm can be caused by act or omission. PRIN 2A.2.11G says a firm with an ongoing relationship must avoid foreseeable harm throughout the lifecycle of the product.
For an adviser firm, omission is the live risk. The review that slipped a year. The client whose charges stayed the same while the service shrank. These harms are foreseeable because the firm’s own back office already holds the data. The question is whether anyone has looked at it client by client.
Rule three: enable and support customers to pursue their financial objectives
PRIN 2A.2.14R says a firm must enable and support retail customers to pursue their financial objectives. For advisers, the guidance at PRIN 2A.2.17G matters most: a firm giving advice can rely on the objectives a client has disclosed, unless it knows or could reasonably be expected to know that information is manifestly out of date, inaccurate or incomplete.
Objectives go stale. A fact find completed before a client retired, sold a business or lost a partner is unlikely to describe what that client wants now. PRIN 2A.2.19G expects a firm that becomes aware, or should reasonably have become aware, of a client’s objective to consider how to support progress towards it. A review cycle that skips the clients who need it most fails this rule quietly.
What evidence of the cross-cutting rules looks like
A policy statement says what a firm intends. Evidence shows what happened, for each client. For an adviser firm that means being able to produce, for every client paying an ongoing fee:
- the fee taken over the period
- the service delivered, with dates
- the date of the last review and when the client’s objectives were last updated
- the cost to the firm of serving that client
Firm averages hide the clients the rules are written to protect. An average review rate can look healthy while a long tail of clients has heard nothing for two years. We cover the same problem from other angles in fair value assessments built on firm averages, the Consumer Duty board report and annual review files under a Section 165 request.
Where Pillar fits
Pillar gives no regulated advice and never makes a decision about a client. The firm and its advisers keep every advice decision.
Pillar Lens reads a firm’s Intelliflo data and puts every client on one line: ongoing fee, allocated cost to serve and assets under management. It shows which clients cost more to serve than they pay and where service records are missing.
The client review service runs reviews in the firm’s own brand, on its own systems, for the clients it chooses, starting with those below its profitability threshold. Pillar takes the preparation, the meeting, the write-up and the filing. Anything that needs advice goes back to the adviser.
If you want to see what your own book looks like against the three rules, talk to us.
Frequently asked questions
What are the three Consumer Duty cross-cutting rules?
A firm must act in good faith towards retail customers, avoid causing foreseeable harm to them, and enable and support them to pursue their financial objectives. They are set out in PRIN 2A.2 of the FCA Handbook (rules 2A.2.1R, 2A.2.8R and 2A.2.14R).
Do the cross-cutting rules apply to existing clients as well as new ones?
Yes. PRIN 2A.2.11G says a firm with an ongoing relationship with a retail customer must avoid foreseeable harm throughout the lifecycle of the product. For an adviser firm that covers every client paying an ongoing fee.
Can an adviser firm rely on the objectives in a client's fact find?
Usually, yes. PRIN 2A.2.17G says an advisory firm can rely on disclosed objectives unless it knows or could reasonably be expected to know they are manifestly out of date, inaccurate or incomplete. An old fact find for a client whose circumstances have changed is the case to watch.
Sources: FCA Handbook, PRIN 2A.2 Cross-cutting obligations, effective 31 July 2023, section last updated 26 June 2026; FCA, About the Consumer Duty, last updated 23 October 2026. Both read 3 November 2026. General information for regulated firms, not regulatory or legal advice.