FCA Consumer Duty Training: What Your Staff Need and How to Prove It Works

The FCA Consumer Duty expects everyone whose work affects retail customers to understand their part in delivering good outcomes. It also expects your firm to prove that understanding shows up in behaviour.

When the Duty arrived in July 2023, most firms ran a compliance training module, pushed completion over the line, and moved on. With a hard deadline, that made sense. Three years on, the FCA is asking a harder question: did that training change how your people treat customers?

If you run compliance, that question lands on you, and a completion report won't answer it.

This guide covers what the FCA found in 2026, which training each team needs, and how to prove it changes behaviour and customer outcomes.

What the FCA found about Consumer Duty training in 2026

Two FCA reviews in 2026 found that firms have Consumer Duty training in place but often can't show it changing how staff behave.

The outcomes monitoring review, published 27 July 2026, includes a section headed "Culture described and supported by training, but not reflected in behaviour or incentives." The FCA found that firms' Duty training "often amounts to describing a culture at a high level", with little evidence of how culture "actually affects their decisions."

In September, review of payments firms found some that "had policies and training in place but were not always able to show how these were working in practice."

The stronger firms took a different route; where weak staff skills caused poor outcomes, they responded by "providing targeted training, clearer expectations and ongoing supervision." The FCA's consumer support review, updated in July 2026, found 66% of surveyed firms had specialist vulnerability training, such as teaching front-line staff to spot the signs.

Who needs which Consumer Duty training?

Everyone whose work affects retail customers needs one shared Consumer Duty module, followed by training specific to their role.

The shared module covers the cross-cutting rules: act in good faith, avoid causing foreseeable harm, and enable and support customers to pursue their financial objectives. After that, training should follow the job and the risks each team actually handles.

A product manager setting a fee and a call handler taking a hardship call face different risks; if you give them the same slides, neither gets what they need.

How to prove your Consumer Duty training works

You prove Consumer Duty training works by showing a clear line from training, to behaviour, to customer outcomes. These four steps draw that line for the FCA.

1. Benchmark before and after. Test what people know before and after training, using scenario questions where they choose what they'd do.

2. Report by role and team. Break results down so managers can see where the gaps are and follow up.

3. Put training next to outcome data. Compare training records with measures such as repeat contact and complaints. The FCA rated evidence stronger where firms "tested whether interventions reduced repeat contact."

4. Retrain where the data points. Target the teams your outcome data flags, rather than re-running the whole programme.

That four-step loop is how we build compliance programmes for regulated firms at  Learning People. Firms add their own policies to the courses, then training is assigned by role, location, jurisdiction, and regulatory mandate, starting from a new joiner's first day. AI conversation simulations let staff practise high-stakes customer moments before they happen. Reporting then shows completions and learning gaps by role and region. It's ready for the board and points to the teams that need retraining.

Discover your team's Consumer Duty training needs in a free 30-minute consultation

If your Consumer Duty record shows completions and not much else,  a free consultation is the place to start. We'll look at which teams sit closest to your outcome data, and whether a skills benchmark and a role-based compliance training plan would close the gap.