This Practice Note provides an overview of the European Venture Capital Funds Regulation (EU) 345/2013 (the EuVECA Regulation) as amended by Regulation (EU) 2017/1991, Regulation (EU) 2019/1156 and Regulation (EU) 2023/2869. The EuVECA Regulation is a specialist alternative investment fund (AIF) regime available to alternative investment fund managers (AIFMs) under the Alternative Investment Fund Managers Directive (2011/61/EU) (AIFMD). AIFMs managing qualifying venture capital funds can elect to use the ‘EuVECA’ designation for these funds, allowing them to market to professional and certain high net-worth investors throughout the EU under the EuVECA marketing passport. The EuVECA regulatory framework The EuVECA Regulation was introduced alongside Regulation (EU) 346/2013 on European social entrepreneurship funds (the EuSEF Regulation). The EuSEF Regulation, as amended, is beyond the scope of this Practice Note, but is covered in Practice Note: The European Venture Capital Funds (EuVECA) Regulation—essentials. On 1 March 2018, Regulation (EU) 2017/1991 amending the EuVECA Regulation and the EuSEF Regulation (the Amending Regulation) took effect. The changes set out in the Amending Regulation were (among other things) intended

This checklist is designed to assist practitioners in understanding and applying the FCA’s Consumer Duty requirements for demonstrating fair value. This checklist should be read alongside other Consumer Duty practical guidance: • for information on the main elements of the Consumer Duty with general application, see Practice Note: The FCA Consumer Duty—essentials; for a suite of sectoral guidance and checklists see: Consumer protection and FCA Consumer Duty—overview • for key developments relating to the FCA’s Consumer Duty, see: The FCA Consumer Duty—timeline Background Under the Consumer Duty, there are four outcomes that cover the key elements of the firm-customer relationship. The second outcome is the Price and Value Outcome. This centres on an overarching obligation that products must offer ‘fair value’. Under PRIN 2A.4: • value is defined as the relationship between the amount paid by a retail customer for the product and the benefits they can reasonably expect to get from the product; and • a product provides fair value where the amount paid for the product is reasonable relative

This Checklist outlines the Financial Conduct Authority’s (FCA) Consumer Duty priority areas of focus. The FCA’s Consumer Duty focus areas and priorities are as follows: • embedding the Duty and sharing good practice • supporting firms to deliver good outcomes under the Price and Value Outcome • meeting FCA and the Information Commission’s Office (ICO) expectations around vulnerability, data sharing, and data protection expectations • sector-specific focus areas, and • realising benefits through

This checklist sets out good practice identified by the Financial Conduct Authority (FCA) in relation to the implementation of the FCA’s Consumer Duty and poor practice based upon the FCA’s identification of areas for improvement. It also lists the FCA’s sector-specific implementation portfolio letters alongside links to sectoral practical guidance. It addresses implementation of the following aspects of the Consumer Duty: • governance and oversight • culture, staff and the Senior Managers and Certification Regime (SM&CR) • the Consumer Duty’s Four Outcomes: ◦ Products and Services Outcome ◦ Price and Value Outcome ◦ Consumer Understanding Outcome ◦ Consumer Support Outcome • vulnerable consumers • third parties (working across the manufacturing and distribution chain) • data strategies to monitor consumer outcomes • deliverability of Consumer Duty implementation Overview The Consumer Duty was implemented in a phased approach: • the Duty came into force on 31 July 2023 for new and existing products and services that are open to sale (or renewal), and • from 31 July 2024, the Duty applied to products

Overview In order for firms to meet their obligations under the Financial Conduct Authority (FCA)’s Consumer Duty, manufacturers and distributors require information about key aspects of a product or service, including its characteristics, target market and the evidence relating to consumer outcomes. Information sharing requirements are a key component of complying with the Duty, ensuring firms can quickly address issues to prevent consumer harm and deliver good consumer outcomes. This Checklist sets out the responsibilities of manufacturers and distributors to share information within the distribution chain and make notifications to other firms and to the FCA under the Consumer Duty, specifically under PRIN 2A and FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty. It addresses the obligations to share information or notify other firms in the distribution chain when harm or potential harm is identified and to notify the FCA regarding firms in the chain. It further addresses data protection obligations and competition law considerations. For information on the Consumer Duty’s application and its component parts see Practice Note: The FCA

This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for payments and electronic money (or e-money) firms. In this Practice note, a payments firm refers generally to a firm that falls within the definition of a ‘payment service provider’ (or PSP) for the purposes of the Payment Services Regulations 2017, SI 2017/752 (PSRs 2017), which includes authorised payment institutions, small payment institutions and registered account information service providers. References to an e-money firm means an authorised electronic money institution or a small electronic money institution (in accordance with the Electronic Money Regulations 2011, SI 2011/99 (EMRs 2011)). At a high level, the Consumer Duty (or Duty) applies to firms conducting regulated activities in the UK, within the FCA’s regulatory remit. While certain payment and e-money firms will have a direct relationship with retail customers, others may only have an indirect relationship due to their involvement

FORTHCOMING CHANGE : On 29 June 2026, the FCA published CP26/23 Consumer Duty: scope and proportionality, proposing targeted changes to its rules and non-Handbook guidance to clarify the scope of the Consumer Duty and support its proportionate application. The proposals include generally limiting the Duty to retail market business involving UK-resident customers, clarifying its application to activities and firms in distribution chains, and refining expectations concerning reliance between firms, vulnerable customers, information gathering, outcomes monitoring and board reporting. The Financial Conduct Authority’s (FCA) Consumer Duty places an increased emphasis on firms putting the needs of their customers first, by creating a requirement that they act to deliver good outcomes for retail consumers. The Duty came into force on 31 July 2023 for new and existing products or services that are open to sale or renewal. On 31 July 2024, the Duty came into force for closed products or services. This presents a development for pension product providers and those who manage legacy

This Practice Note considers the implications of the Financial Conduct Authority (FCA)’s Consumer Duty (Duty) to FCA authorised firms that have permission to carry out the following activities: (i) managing an alternative investment fund (AIF); (ii) managing an undertaking for collective investment in transferable securities (UCITS); or (iii) managing investments. In particular, it considers the main elements of the Duty, including its application and scope (relevant exclusions; the meaning of material influence, and the proportional application of the Duty), the Consumer Duty principle, the cross-cutting rules and the four outcomes as they apply to asset management firms. For information on the main elements of the Consumer Duty with general application, see Practice Note: The FCA Consumer Duty—essentials. The Duty came into force for new and existing products and services that are open for sale (or renewal) from 31 July 2023 and for closed book products and services on 31 July 2024. There are important developments

This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for credit unions. The Consumer Duty came into force for new and existing products and services that are open for sale (or renewal) on 31 July 2023. For products and services where existing contracts with retail customers were entered into before 31 July 2023, but that have not been marketed or distributed to retail customers (including by way of renewal) on or after 31 July 2023 (hereinafter referred to as closed products), the Consumer Duty came into force on 31 July 2024. For developments, see The FCA Consumer Duty—timeline. For information on the main elements of the Consumer Duty with general application, see Practice Note: The FCA Consumer Duty—essentials. For further materials and sector specific practical guidance, see: Consumer protection and FCA Consumer Duty—overview. Key points for credit unions • the FCA Consumer Duty applies to all regulated activity undertaken by credit unions • even where credit unions are undertaking lending activity which is exempt from

Firms in the Financial Conduct Authority’s (FCA’s) mainstream consumer credit lender (MCCL) portfolio, known as MCCL firms, provide unsecured overdrafts, loans or credit cards which are regulated under the Consumer Credit Act 1974 (CCA 1974). The Consumer Duty presents particular implementation challenges for MCCL firms which are explored in this Practice Note. This Practice Note considers the application of the Consumer Duty to MCCL firms, and includes details of: • the scope of the Consumer Duty’s application to MCCL firms • the interaction between the Consumer Duty and pre-existing FCA rules and guidance • the implications for MCCL firms in complying with the cross-cutting rules under the Consumer Duty • the implications for MCCL firms in delivering the four consumer outcomes under the Consumer Duty • areas of potential difficulty for MCCL firms • the implications for MCCL firms in implementing the Consumer Duty for closed products, and • practical steps for MCCL firms in embedding the Consumer Duty The deadline

This Practice Note considers the application of the FCA’s Consumer Duty to retail banks and building societies. For ease of reference, the term ‘retail bank’ is used throughout this Practice Note to refer to both types of institutions, except where there is cause to distinguish. The Consumer Duty came into force for new and existing products and services that are open for sale (or renewal) on 31 July 2023. At a high level, the Consumer Duty applies to firms conducting regulated activities in the UK, within the FCA’s regulatory remit. Retail banks, given the wide range of products and services offered, will have direct relationships with retail customers, as well as potentially indirect relationships due to their involvement in a distribution chain that involves a retail end customer. The Consumer Duty applies to both; however, the extent to which it applies will depend upon the firm’s responsibility for determining or materially influencing retail customer outcomes. This Practice Note considers the application of the Consumer Duty to retail

Introduction This Practice Note considers the implications of the Financial Conduct Authority’s (FCA) Consumer Duty for wholesale firms. In this Practice Note, a wholesale firm refers generally to a firm that operates in the financial services wholesale markets and does not have a direct relationship with retail customers in relation to the provision of a product or service. As the Consumer Duty is limited to a firm’s retail market business and financial promotions which are addressed to, or disseminated in such a way that they are likely to be received by, a retail customer, certain wholesale activities are not captured by the Duty. Nevertheless, where that business involves operating in a distribution chain that involves an end retail customer, the Consumer Duty applies to the extent that the wholesale firm is responsible for determining or materially influencing retail customer outcomes. This Practice Note considers the scoping exercise for wholesale firms, including relevant exclusions, the meaning of material influence, and the proportional