Information on section 166 reviews and consumer duty - March 2025

Please see the table below that sets out the number of Section 166 reviews we have commissioned since the introduction of the Consumer Duty on 31 July 2023:

*Some numbers may differ from our annual report data as some reviews may have been cancelled after publication.

We can confirm that of the 105 Section 166 reviews undertaken and listed above, 27 were related at least partially to the Consumer Duty. It should be noted that not all of these reviews are exclusively related to the Duty. Some covered wider issues with the Consumer Duty aspect forming one element of that wider review.

We publish aggregate annual costs for Section 166 reviews in our Annual Report. The relevant information can be found on our Skilled Person Reviews page, under historic use.

We have estimated this figure to be £11.4m for the period covering 31 July 2023 to 31 March 2024 in the FY 2023/24. The costs of reviews incurred in FY 2024/25 are not yet available and will be published in the FCA’s Annual Report in July 2025.

We have estimated that the total cost of the 27 reviews related at least partially to the Consumer Duty is £6m for the period from 31 July 2023 to date. As stated above, some of these reviews cover the Consumer Duty as only one element of a wider review. Additionally, not all the reviews are yet complete. This is therefore a ‘best endeavours’ estimate which does not correlate precisely to a cost for Consumer Duty elements only of the s166 reviews considered, and the final figures may still change once more reviews have been completed.

Many of the reviews are still ongoing, and it’s too early to determine what the full extent of follow-up action by the FCA will be. The FCA has voluntary restrictions in place for a number of these firms whilst the reviews are ongoing to prevent further harm from arising.

As at the date of this response, there have been no formal enforcement investigations opened as a direct result of Section 166 reviews relating to the Consumer Duty. However, enforcement investigations are only one of the tools we use – co-operation, assertive supervision and intervention powers are also key in dealing with harm. Where the reviews have been completed, we have followed up with supervisory actions ranging from the use of tools such as attestations, redress and remediation plans, and requirements for firms to change processes and take action in response to the findings from the reviews.