Life Insurance × Marketing Comms — United Kingdom · published 2026-05-28 · methodology v2.1

Consumer testing obligations under PRIN 2A and FG22/5

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007

What the RLB Specialist Panel found

1. Consumer testing obligations under PRIN 2A and FG22/5

Question (paraphrased to protect IP): Are firms required to conduct consumer testing under the Consumer Duty, and is any such obligation a binding rule or guidance under PRIN 2A?
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 stated that a specific provision in PRIN 2A.5 constitutes a binding rule requiring firms to test the effectiveness of their communications "where appropriate", and further described FCA finalised guidance on consumer testing as effectively mandatory in practice — a characterisation directly contradicted by the regulatory text.
What the regulator actually says: FG22/5 contains guidance (not rules) recommending firms "should" consider consumer testing of communications. PRIN 2A.5 requires firms to act to deliver the good consumer understanding outcome but prescribes no specific testing methodology.
Why the AI went wrong: The AI cited a rule reference that does not exist in the FCA Handbook and conflated the FCA's non-binding finalised guidance with a binding regulatory requirement, collapsing the legally significant distinction between rules and guidance that the Handbook marks explicitly.
Cited source(s):
https://handbook.fca.org.uk/handbook/PRIN/2A/5.html — Pretextual
https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf — Pretextual

Impact for this audience

A Marketing & Communications team at a life insurance firm that relies on this AI response when drafting internal policy on communications approval could embed an incorrect rule reference and a false characterisation of guidance as mandatory into its standard operating procedures. Every campaign, financial promotion, or consumer communication reviewed under that framework would be assessed against obligations the firm believes are binding but that the FCA Handbook does not actually impose in that form. If the FCA subsequently reviews the firm's Consumer Duty implementation, a marketing approval policy built on a fabricated rule reference would be difficult to defend; the firm could face requirements to remediate its framework, review communications already issued under it, and in serious cases face supervisory action under the FCA's Consumer Duty enforcement powers.

References — raw findings (per AI model)

RLB-H-GB-FCA-CONSUMER-DUTY-PS22-9-Q007-Sonnet46 Claude Sonnet 4.6 (web search on)

This finding also affects

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). "Consumer testing obligations under PRIN 2A and FG22/5 — Life Insurance × Marketing Comms — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007. RegLegBrief AI Hallucination Research, published 2026-05-28. https://reglegbrief.com/audiences/sectors/gb/life_insurance/marketing_comms/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/

APA 7th edition

RegLeg Specialist Panel. (2026). Consumer testing obligations under PRIN 2A and FG22/5 [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/life_insurance/marketing_comms/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/

Bluebook / OSCOLA (US + UK legal)

RegLeg Specialist Panel, Consumer testing obligations under PRIN 2A and FG22/5 [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007], RegLegBrief AI Hallucination Research (May 28, 2026), https://reglegbrief.com/audiences/sectors/gb/life_insurance/marketing_comms/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/.

BibTeX

@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q007,
  author    = {RegLeg Specialist Panel},
  title     = {Consumer testing obligations under PRIN 2A and FG22/5},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q007},
  url       = {https://reglegbrief.com/audiences/sectors/gb/life_insurance/marketing_comms/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-007/}
}

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