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Financial Advisory × Legal — United Kingdom · published 2026-05-28 · 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

2. 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, and 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: AI tools produce detailed, attributed accounts of specific changes between the consultation paper and the final rules — including precise claimed wording differences such as a shift from requiring firms to identify outcomes that were "worse" for one group to identifying where any group experiences "different outcomes", and statements about PROD 3 alignment — presenting these as documented fact rather than as uncertain reconstruction.
  • What the regulator actually says: The specific textual differences between CP21/36 and PS22/9 are not recoverable from publicly available sources with sufficient precision to verify the particular attributed changes the AI describes.
  • Why the AI went wrong: AI tools appear to have generated plausible-sounding draft-versus-final distinctions by inference, presenting them with the same confidence and specificity as verifiable facts; the output contains a mixture of claims that may be accurate and claims that are not traceable to primary sources, with no signal to the reader about which is which.
  • Cited source(s):
  • https://www.womblebonddickinson.com/uk/insights/articles-and-briefings/consum... — Pretextual
Impact for this audience

A Financial Advisory firm whose Legal team relies on AI-generated accounts of what changed between CP21/36 and PS22/9 may have built its Consumer Duty implementation around rule requirements that were never actually finalised in the form described. If the claimed outcome-monitoring scope change (from 'worse' outcomes to 'different outcomes') or the PROD 3 alignment provision are not accurately reproduced, the firm's monitoring framework and product governance approach may be miscalibrated against the actual final rules. The cost of discovering this at the point of an FCA supervisory review includes the expense of a retrospective implementation audit, potential remediation across affected client populations, and the reputational consequence of disclosing to the FCA that firm-wide policy was built on unverified AI output. The FCA has been explicit that it expects firms to take ownership of their Consumer Duty implementation, and inability to trace policy decisions to verified primary sources is unlikely to be viewed as a mitigating factor.

References — raw findings (per AI model)
This finding also affects
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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 × Legal — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q017. RegLegBrief AI Hallucination Research, published 2026-05-28. https://reglegbrief.com/audiences/sectors/gb/financial_advisory/legal/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/legal/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 28, 2026), https://reglegbrief.com/audiences/sectors/gb/financial_advisory/legal/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/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-017/}
}
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