Consumer Duty Fair Value: FG22/5 Existing Products

The Consumer Duty asks firms to consider whether there is a reasonable relationship between what a customer pays and what they receive. That raises hard questions for products already on the market, products closed to new customers, and products sold through other firms. The FCA's Consumer Duty guidance, FG22/5, published in July 2022, speaks to several of them. This guide summarises the parts we could read. It supports our Fair Value and Pricing Outcomes course overview and follows our summary of the FCA's price and value good and poor practice page.

Existing and closed products

FG22/5 says firms should consider whether there is a reasonable relationship between price and benefits for existing and closed products too. It adds that firms are not judged with hindsight, so the Duty does not require firms to amend charges for existing customers where assumptions made at the time later prove incorrect. Firms should review assumptions for products still on sale, and may take account of early-year benefits that are covered by later costs.

Vested rights

The guidance also says firms are not expected to give up vested contractual rights, such as annual fees already due or exit charges, when addressing potential harm. In our reading, that sets a limit on how far the Duty reaches into existing contracts, though it does not remove the obligation to consider fair value.

Value in the round

FG22/5 says a product that meets the other elements of the Duty is much more likely to offer fair value. This links fair value to product design, customer understanding and customer support, which is why firms are told not to assess price in isolation. In the cross-cutting rules, the guidance says firms should act to avoid foreseeable harm by considering whether charges represent fair value for different customer groups, and by amending charges where a value assessment finds the price does not provide fair value.

Transparency and complex charges

The guidance gives designing products where pricing and charges are not presented so customers can easily understand the total cost as an example of not acting in good faith. It also says complex charging structures or differential pricing may carry a greater risk of poor outcomes. Together with the vested rights point, this shows that FG22/5 covers both what firms charge and how they present it.

The distribution chain

FG22/5 treats price and value as a shared responsibility across the distribution chain. A co-manufacturer with a key role in setting charges has more significant obligations. Platform providers must obtain enough information to understand the value assessment and to see whether their own remuneration would stop the product offering fair value. Manufacturers should consider how a product is distributed and review its distribution over time. Our guide to MiFID product governance covers a related set of manufacturer and distributor duties.

Vulnerable customers

The guidance says firms should identify when groups of customers, including those with characteristics of vulnerability, receive systematically poorer outcomes. For pricing teams, that means looking at outcomes by customer group, not only at average price.

Reading FG22/5 alongside the 2026 FCA page

The FCA's price and value good and poor practice page, updated in July 2026, builds on the same ideas. It says the Consumer Duty rules do not set prices or require the lowest price, and that non-financial costs such as time and effort also count. It describes poor practice that FG22/5 helps explain, including assessments written after the event to justify existing pricing, benchmarking that treats market-average pricing as proof of value, and mitigating action that stops at a letter telling customers they receive a low rate. The 2026 page also says its examples do not create new rules. Taken together, the two documents suggest the FCA expects firms to keep contemporaneous reasoning and to act on what an assessment finds.

Using this in a pricing or product role: our suggestions

These steps are our suggestions, not requirements in the guidance.

• List closed and legacy products and check each has a dated value review.
• Where a product is sold through others, record what value information you passed down the chain and what you received.
• Split outcome data by customer group, including customers with characteristics of vulnerability.
• Record assumptions at the time of pricing so they can be defended later without hindsight.

For structured learning, browse our CPD courses.

What we could not confirm

The text we could access was cut off at paragraph 5.44, so Chapter 7 of FG22/5, which deals directly with the price and value outcome, was not read. We have therefore not described the rule text in the Handbook or the detailed fair value assessment requirements. The guidance is dated July 2022 and the FCA has published later material, so check the current position. This post covers UK firms only and is general information, not legal advice.