On 29 July 2022, the FCA updated its webpage on authorisations to make firms and individuals aware that, although the Consumer Duty does not come into effect until the end July 2023, those looking to be authorised by the regulator will need do demonstrate compliance with the Duty from now on.

The regulator clarified that its Authorisations unit assessment of applicants will be “forward looking”. This means that firms and individuals seeking FCA authorisation (or to vary their permissions) must be able to demonstrate to the regulator that they can comply with the regulator’s Consumer Duty rules and guidance (as relevant) on an ongoing basis.

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“..any firm or individual applying for authorisation (and those applying to vary their permissions) will have to demonstrate that they can meet the requirements of the Consumer Duty, as they relate to them, from now on.”

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