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Practitioners — Financial Advisers · published 2026-05-26 · methodology v2.1

Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9)

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017
What the RLB Specialist Panel found

8. Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9)

  • Question (paraphrased to protect IP): Were there significant differences between the Consumer Duty as proposed in CP21/36 and the final rules in PS22/9? What specific provisions were changed?
  • Source regulation: Consumer Duty (PS22/9 + PRIN 2A), Financial Conduct Authority (Regulator portal: https://www.fca.org.uk)
  • What AI assistants typically say: Multiple AI tools gave similar confident responses listing specific changes between CP21/36 and PS22/9. One listed six detailed changes including the split implementation timeline, scope and distribution chain clarifications, refinements to the foreseeable harm wording, and confirmation that a private right of action would not be introduced. The other listed five specific differences with comparable detail on wording changes, outcomes monitoring scope, and product governance alignment.
  • What the regulator actually says: The specific differences between the CP21/36 draft and the PS22/9 final rules were not reliably recoverable from available regulatory sources at the point of testing.
  • Why the AI went wrong: Both AI tools presented detailed and specific accounts of CP21/36-to-PS22/9 changes without acknowledging any uncertainty about the accuracy of their characterisation. Where the specific framing of wording changes and rule modifications cannot be verified against the primary documents, confident unhedged answers of this kind carry a real risk that some details are plausible reconstruction rather than verified fact. A practitioner using this account in a regulatory submission or training material would have no way to identify which elements have a verified basis.
  • Cited source(s):
  • https://www.fca.org.uk/publication/consultation/cp21-36.pdf — Pretextual
  • https://www.womblebonddickinson.com/uk/insights/articles-and-briefings/consum... — Pretextual
Impact for this audience

A Financial Adviser advising a client on the historical development of the Consumer Duty — for example, to understand what the FCA changed between consultation and final rules and why — may be advising on an implementation timeline, a past regulatory decision, or the provenance of a specific provision. If the AI's confident but unverified account of CP21/36-to-PS22/9 differences is inaccurate in its detail, the adviser has no way to know without checking the primary documents themselves. For regulatory work that depends on understanding what the FCA specifically decided and why, a plausible but unverified reconstruction from an AI tool is not a safe substitute for reading the actual documents.

References — raw findings (per AI model)
This finding also affects
← Previous finding Finding 7. FCA senior officials' public statements on first-year Consumer Duty compliance Next finding → Finding 9. Consumer Duty scope exclusions — reinsurance, group insurance, and large commercial risks
Cite this finding

Each finding has a stable Citation ID (RLB-F-… for aggregated case-study findings, RLB-H-… for raw per-model hallucinations) — like a DOI, the ID always resolves to the canonical finding even if URLs change.

Plain text 
RegLeg Specialist Panel (2026). "Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9) — Practitioners — Financial Advisers." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/
APA 7th edition 
RegLeg Specialist Panel. (2026). Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9) [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/
Bluebook / OSCOLA (US + UK legal) 
RegLeg Specialist Panel, Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9) [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/.
BibTeX 
@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q017,
  author    = {RegLeg Specialist Panel},
  title     = {Differences between the Consumer Duty consultation draft (CP21/36) and the final rules (PS22/9)},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017},
  url       = {https://reglegbrief.com/audiences/practitioners/gb/financial-advisers/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/}
}
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