What introducers should keep on record under the Consumer Duty
The Duty applies to regulated firms along the distribution chain, introducers included. A short note on each referral answers most later questions.
What the Duty is
The Consumer Duty is the FCA's Principle 12, which requires firms to act to deliver good outcomes for retail customers.2,1
It came into force on 31 July 2023 for products and services open to sale or renewal, and on 31 July 2024 for closed products. Three cross-cutting rules sit alongside it: act in good faith, avoid causing foreseeable harm, and enable and support customers to pursue their financial objectives.2
Who it applies to
The Duty applies to regulated firms across the distribution chain, including those that introduce customers to an adviser or lender and never arrange the loan themselves. A regulated introducer has its own obligations, separate from the adviser's.3
The four outcomes, from an introducer's seat
The FCA's guidance describes four outcomes for retail customers. Each has a counterpart in how an introduction is made and recorded.3
- Products and services: refer clients whose needs a secured loan could plausibly meet, and say so when it probably can't.
- Price and value: be open about any fee you receive for the introduction, so the client can weigh it.
- Consumer understanding: explain that the adviser, not you, will recommend whether a product is suitable, and that the loan would be secured on their home.
- Consumer support: make it easy for the client to ask questions, change their mind or reach the right person.
What to keep on file
No new system is needed. A short, consistent note for each referral does most of the work: what the client asked for, what you told them, and why an introduction to a specialist adviser was appropriate. That note answers most questions a network, lender or adviser will ask later.
If your firm already has vulnerable-customer or fair-value processes, link the referral note to them rather than repeating them. A note on its own doesn't show the firm has met all of its Consumer Duty obligations.3
Records matter in second charge in particular. When the FCA reviewed the market in March 2026, inadequate record keeping was one of the four issues it named, alongside affordability checks, debt-consolidation advice and fees.4
What to say to clients
Plain wording that covers the outcomes above:
- "I'm introducing you to an adviser. They'll look at your circumstances and recommend whether this loan suits you."
- "The loan would be secured on your home, alongside your existing mortgage."
- "I receive a fee for this introduction, and I'll tell you how much."
Sources
- 1FCA, “Consumer Duty (firm guidance hub)”Overview of the Duty and links to the FCA's rules and guidance.
- 2FCA, “PS22/9: A new Consumer Duty – Feedback to CP21/36 and final rules (July 2022)”Principle 12, the cross-cutting rules, the four outcomes and the implementation dates.
- 3FCA, “FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty (July 2022)”The four outcomes and how firms in a distribution chain apply them.
- 4FCA, “Second charge mortgage firms told to raise standards for consumers (12 March 2026)”The four issues the FCA identified, including inadequate record keeping.
Information only, not advice. Spotted an error? See our corrections policy.