Pillar Client Services has filed its formal response to the FCA's CP26/10 consultation today, 12 May 2026, ten days ahead of the 22 May deadline. The full response is published, in full, with no redactions, at pillarcs.co.uk/resources/cp26-10-response. You can read it, download it, share it, or use any of it.
Why we filed early
Most consultation responses arrive in the final 48 hours. The FCA reads early submissions with more time. The 16 April 2026 Consumer Duty Board Reports observations gave us new evidence the response needed to fold in. We saw no reason to wait.
What the response argues
CP26/10 is the right direction. Replacing the mandatory annual review with a needs-based cadence forces firms to defend the service against Consumer Duty outcomes rather than against a frequency rule. Formalising the disengaged client expectation is the single most important Consumer Duty clarification in the consultation.
Read alongside the FCA's 16 April distribution chain observations, the policy gives the industry a clear instruction. The principal firm cannot delegate the duty. It can delegate the execution, provided the audit trail is principal-firm-grade and the oversight is documented. That is the model Pillar is built to support.
Our response asks the FCA to make this explicit in the final policy. Outsourced non-advice review delivered under data-processor governance is a legitimate route to proportionate service. Audit trails generated by third party providers, surfaced to the principal, satisfy the Consumer Duty evidence requirement. Reasonable re-engagement steps for disengaged clients can be delivered by non-advice third parties under documented principal oversight.
What we put on record
We covered nine questions: Q7 (frequency), Q8 (additional guidance), Q9 (proportionality), Q10 (charging for related services), Q15-16 (disengaged clients), and Q22 (cost-benefit analysis). We left the questions outside our practical experience to firms with that expertise.
We supplied operational evidence from the live deployment at Paterson Financial Planning. April 2026: 20 reviews completed, 3 escalations to the regulated adviser, £11,000 of revenue generated from those escalations, internal Quality Audit score 4.12 of 5, GREEN. The escalation revenue covered the cost of the review programme 2.4 times over in the month. The audit trail is produced as a by-product.
The Consumer Duty mapping
We attached the Pillar Consumer Duty mapping as a named exhibit. It maps our model to all four Outcomes and shows where the principal firm's responsibility starts and stops. The mapping is in the PDF, page fifteen.
Where this goes next
The FCA is expected to publish the policy statement in late 2026. The FCA also confirmed in the 16 April observations that it will consult on changes to rules and guidance for distribution chains during 2026. Those two consultations will land into the same regulatory environment. Firms that read both as a single brief will be better placed than firms that read them in isolation.
We will track both, summarise the FCA's response, and explain what it means for adviser firms with long-tail books.
Read the response
The full response is at pillarcs.co.uk/resources/cp26-10-response. Sixteen pages, including the Consumer Duty mapping and the April 2026 pilot data. The PDF is downloadable, free to share, and free to cite. If your firm wants to file its own response, you may use ours as a starting point.
If you want to talk through how CP26/10 lands in your firm specifically, the contact page is one click away.