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On June 20, 2026, the Financial Conduct Authority (FCA) published Consultation Paper CP26/23 proposing targeted changes to the scope and application of the Consumer Duty (the Duty), which came into force in July 2023. The consultation seeks feedback on proposals to clarify where the Duty applies and ensure it is applied proportionately, particularly for firms in wholesale markets and complex distribution chains. The FCA proposes to limit the Duty's territorial scope to retail customers usually resident in the United Kingdom, removing business with non-UK customers from the Duty's scope while retaining application where there remains clear risk of harm to UK-connected consumers. The proposals also aim to provide greater certainty on the Duty's scope by clarifying key concepts including retail market business, distribution chains, material influence, and principal versus secondary manufacturers. The FCA proposes specific exclusions for certain activities sufficiently remote from retail customer outcomes, including market making, merchant acquiring, and certain custody and depositary services. The consultation proposes proportionate application of the Duty through clarifications on firms' roles and responsibilities across distribution chains, including that firms are only responsible for their own activities unless other regulation or contracts require otherwise. The FCA proposes guidance on reasonable reliance on other firms, proportionate information gathering, and board reporting commensurate with firms' roles. The proposals also address how the Duty interacts with other product governance and disclosure requirements, particularly for wholesale firms manufacturing retail investment products. The comment period ends on Friday, September 18, 2026. The FCA expects to publish a policy statement summarising responses and make final rules in the first quarter of 2027. The consultation includes a cost-benefit analysis estimating total one-off costs to firms between £35.6 million and £106.0 million, with a central estimate of £92.1 million.