On 9 December 2025, the Financial Conduct Authority (FCA) published a consultation paper (CP25/37) setting out proposals designed to provide targeted clarifications of the FCA Handbook.

Background

The FCA sets out in CP25/37 that this consultation forms part of its Consumer Duty Requirements Review and that this follows its July 2024 call for input on its review of FCA requirements following the introduction of the Consumer Duty and is part of the workplan announced in it March 2025 feedback statement.

Proposals

The FCA explains that it is seeking to reduce administrative burdens on firms and to clarify its rules, and that CP25/37 sets out several individual proposals to support this aim, including:

  • Collective Investment Schemes Sourcebook (COLL) updates: Technical amendments to streamline in COLL 5, including clarifying rules about UK Undertakings for Collective Investment in Transferable Securities’ investment powers.
  • Clients Asset Sourcebook (CASS) amendments: Proposals to change record-keeping rules in CASS 6 and 7, including amending record keeping requirements for certain due diligence relationships, broadening the reconciliation rules, clarifying how the Consumer Duty applies where firms receive or hold client money or assets for retail clients, and adding flexibility in relation to the treatment of money held in client bank accounts relating to back interest earned.
  • Simplifying insurance and funeral plans rules: Proposals to remove certain product-specific rules, including the deletion of Product Oversight and Governance Sourcebook (PROD) 4.5 in relation to expectations for manufacturers and distributor in relation to value measures data and several payment protection insurance and packaged bank accounts-specific eligibility requirements, which the FCA considers are no longer required. The FCA are also proposing to remove certain requirements in relation to funeral plan product reviews.
  • Smaller firms’ guidance: The FCA are also seeking industry input on a proposal to create a smaller firms guide, in particular in relation to where firms have unmet needs for clearer FCA guidance.
  • Handbook references update: The FCA are also proposing to amend and update FCA Handbook references to Principles 6 and 7 to reflect the introduction of the Consumer Duty.

Next steps

The deadline for comments on CP25/37 is 27 January 2026.