Financial Advisory × Compliance — United Kingdom · published 2026-05-26 · methodology v2.1

Changes between CP21/36 consultation and PS22/9 final rules

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017

What the RLB Specialist Panel found

8. Changes between CP21/36 consultation and PS22/9 final rules

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 detailed responses listing specific changes between the consultation draft and the final rules — including implementation timeline splits, scope and distribution chain clarifications, foreseeable harm wording amendments, product governance alignment, and the decision not to introduce a private right of action. Both responses present these details with apparent confidence and without acknowledging any uncertainty about their accuracy.
What the regulator actually says: The specific differences between CP21/36 and PS22/9 were not recoverable for verbatim verification. The available regulatory record does not provide a reliable authoritative account of these changes against which AI responses can be checked.
Why the AI went wrong: Where there is a verifiable gap in accessible regulatory source material, AI tools fill it with plausible reconstruction rather than acknowledging the gap. Some claims — such as the two-stage implementation timeline and the decision on private right of action — are broadly documented, but the specific characterisation of wording changes and other provisions cannot be verified and may reflect training-data inference rather than verified fact. A Compliance team using this output to document how the Duty evolved would be relying on an unverified account.
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 Compliance team using AI-generated accounts of CP21/36-to-PS22/9 differences to document the evolution of its Consumer Duty framework — for example in a board-level implementation review, a regulatory change management record, or external audit workpapers — would be relying on an account of regulatory history that cannot be verified against primary sources. If specific wording changes are mischaracterised, the firm's record of why it interpreted particular provisions in certain ways may be inaccurate. Where the FCA or an external auditor asks the firm to demonstrate how it tracked and implemented the final rules, a documented account based on unverified AI reconstruction is a weak foundation.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q017-Opus47 Claude Opus 4.7 (web search on)
RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q017-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

← Previous finding Finding 7. FCA senior official statements on first-year Consumer Duty compliance Next finding → Finding 9. Dear CEO letters remaining in force after Consumer Duty implementation

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). "Changes between CP21/36 consultation and PS22/9 final rules — Financial Advisory × Compliance — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/

APA 7th edition

RegLeg Specialist Panel. (2026). Changes between CP21/36 consultation and PS22/9 final rules [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Changes between CP21/36 consultation and PS22/9 final rules [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/financial_advisory/compliance/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     = {Changes between CP21/36 consultation and PS22/9 final rules},
  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/sectors/gb/financial_advisory/compliance/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/}
}

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