AI Hallucination ResearchAudiencesSectorsUnited KingdomRetail BankingLegalDetail › Finding
Retail Banking × Legal — United Kingdom · published 2026-05-26 · methodology v2.1

Retail customer definition — charity threshold and sourcebook variation

RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005
What the RLB Specialist Panel found

2. Retail customer definition — charity threshold and sourcebook variation

  • Question (paraphrased to protect IP): Does the Consumer Duty apply to micro-enterprises or small charities? Are they 'retail customers' 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: Multiple AI tools gave similar incorrect responses. Both correctly identified that micro-enterprises and small charities fall within the definition of "retail customer" under PRIN 2A, but each introduced a material error: one AI substituted "annual income" for "annual turnover" as the qualifying measure for charities, while another correctly named charities as in-scope but omitted the specific £1 million annual turnover threshold entirely and also failed to note that the definition varies depending on which FCA sourcebook applies.
  • What the regulator actually says: The definition of retail customer includes individual consumers, micro-enterprises, and charities with annual turnover less than £1 million. The definition varies by sourcebook.
  • Why the AI went wrong: "Turnover" and "income" are distinct accounting concepts, and AI tools appear to conflate them — likely because in everyday language they are used loosely as synonyms, even though they carry different meanings in a regulatory context. The omission of the sourcebook-variation qualifier is a separate failure: AI tools tend to present regulatory definitions as uniform when the source rules themselves contain important scope-limiting caveats.
  • Cited source(s):
  • https://handbook.fca.org.uk/handbook/PRIN/2A/1.html — Pretextual
  • https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf — Pretextual
  • https://handbook.fca.org.uk/handbook/PRIN/2A/5.html — Pretextual
  • https://handbook.fca.org.uk/handbook/prin2a — Pretextual
Impact for this audience

The retail customer definition under PRIN 2A determines whether the Consumer Duty applies to a given counterparty — and an incorrect threshold (annual income rather than annual turnover, or no threshold at all) applied to the charity population could cause a UK Retail Banking firm to either over-scope its Consumer Duty monitoring (adding unnecessary compliance cost) or under-scope it (leaving out-of-scope charities uncovered and creating regulatory exposure). The omission of the sourcebook-variation qualifier compounds the risk: a firm that treats the PRIN 2A definition as universal across all FCA sourcebooks may apply the wrong standard in product-specific regulatory mapping, and the FCA has made clear that firms are expected to understand their obligations at this level of precision.

References — raw findings (per AI model)
This finding also affects
← Previous finding Finding 1. Legal basis of the Consumer Duty — FSMA 2023 disclaimer Next finding → Finding 3. Changes from CP21/36 consultation to PS22/9 final rules
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). "Retail customer definition — charity threshold and sourcebook variation — Retail Banking × Legal — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/
APA 7th edition
RegLeg Specialist Panel. (2026). Retail customer definition — charity threshold and sourcebook variation [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/
Bluebook / OSCOLA (US + UK legal)
RegLeg Specialist Panel, Retail customer definition — charity threshold and sourcebook variation [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/.
BibTeX
@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q005,
  author    = {RegLeg Specialist Panel},
  title     = {Retail customer definition — charity threshold and sourcebook variation},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005},
  url       = {https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/}
}
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