T331 · FCA Consumer Duty · PS22/9 · DPC · AP2 Export

FCA Consumer Duty DPC Mapper

Map your Deferred Payment Credit product against all four FCA Consumer Duty outcomes — Products & Services, Price & Value, Consumer Understanding, and Consumer Support — as required for DPC lenders entering the regulatory perimeter under PS26/1 (effective 15 July 2026). Generates a RAG status dashboard, identified gaps, remediation actions, and cross-cutting rules compliance check.

Mandatory on FCA Authorisation PS22/9 · PRIN 12 · PS26/1 Four Outcomes · Cross-Cutting Rules · RAG Client-Side · Zero PII · CC BY 4.0
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Outcome 01 Products & Services (PRIN 12.2.2R)

Products must be designed to meet the needs, characteristics, and objectives of the target market, and distributed appropriately. Firms must identify a target market and ensure the product is not marketed to consumers outside that definition.

PRIN 12.2.2R: manufacturer must identify target market. FCA expects explicit positive and negative target market characterisation for DPC.
Consumer Duty requires manufacturers to test products meet target market needs before distribution. Outcome modelling (e.g. arrears scenarios) expected for DPC.
PRIN 12: manufacturers must ensure distributors only sell to appropriate consumers. DPC lenders must have contractual controls on merchant/partner distribution.
Consumer Duty requires ongoing monitoring and annual Consumer Duty report. Products must be reviewed at least annually and when material changes occur.
Outcome 02 Price & Value (PRIN 12.2.3R)

The price a consumer pays for a product must be reasonable relative to the benefits received. For DPC: zero APR product, but charges (particularly late fees) must not create unfair overall value. Firms must conduct a Value Assessment.

DPC must be interest-free. Any reversion rate or hidden charges create Price & Value issues. Late fees must be cost-reflective not punitive.
FCA PS26/1 ¶5.3: late fees must be fair, transparent, and cost-reflective. High or uncapped fees likely constitute poor value and Consumer Duty breach.
Consumer Duty Final Rules require a formal written Value Assessment comparing price paid against consumer benefit. For DPC: compare merchant subsidy revenue against consumer cost (late fees, declined credit impact).
Revenue model affects Value Assessment. Consumer-funded models (relying heavily on late fees) attract higher FCA scrutiny on Price & Value outcome.
Outcome 03 Consumer Understanding (PRIN 12.2.4R)

Consumers must receive timely, clear communications enabling informed decisions. For DPC: pre-contract disclosure (CONC 4 / CCD Regs), total cost of credit, repayment schedule, cooling-off rights, and consequences of non-payment must be communicated clearly before credit is drawn.

CONC 4 and Consumer Credit (Disclosure of Information) Regulations 2010: pre-contractual information must be provided in durable medium before agreement. Digital delivery satisfies this for online DPC.
CCA 1974 s.66A: consumer has 14-day right to withdraw from a credit agreement without penalty. Must be clearly communicated under Consumer Understanding outcome.
FCA Consumer Understanding requires marketing to be fair, clear, and not misleading. Consequences of missed payments must have fair prominence (FCA PS26/1 ¶6.4).
Consumer Understanding requires communications to be effective for target market. Legal language alone is insufficient — consumer testing expected for new DPC products.
Outcome 04 Consumer Support (PRIN 12.2.5R)

Consumers must receive the support they need throughout the lifecycle of the product. For DPC: accessible complaints handling, arrears support, debt advice signposting, and fair treatment of consumers in financial difficulty.

DISP 1: complaints must be acknowledged within 5 business days and resolved within 8 weeks. FOS access must be communicated. Consumer Duty elevates this to an outcome.
Consumer Support requires fair treatment in financial difficulty. Must comply with Debt Respite Scheme (Breathing Space) Regulations 2020 where consumer enters scheme.
Consumer Duty and FCA PS26/1 require firms to signpost consumers in difficulty to free debt advice (Money Advice Service, StepChange, Citizens Advice).
Consumer Support requires all consumers, including those with accessibility needs, to be able to access the support they need. Digital-only may disadvantage some consumers.
Consumer Duty DPC Assessment — Four Outcomes RAG
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Consumer Duty Readiness Scores (0–100)
Products & Services
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Price & Value
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Consumer Understanding
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Consumer Support
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Overall Consumer Duty readiness —
Four Outcomes — Detailed RAG Assessment
Cross-Cutting Rules (PRIN 12.4) — All Must Pass
RuleDescriptionAssessmentStatus
AP2 v1.0 · @ainumbers.co/fca-consumer-duty-dpc-v1

Regulatory Sources

[1]FCA PS22/9: Consumer Duty Final Rules (Jul 2022). PRIN 12: four consumer outcomes (Products & Services, Price & Value, Consumer Understanding, Consumer Support) and three cross-cutting rules.
[2]FCA PS26/1: Policy Statement — Regulation of Buy Now Pay Later (Feb 2026). ¶¶5.1–5.15: Consumer Duty application to DPC lenders; ¶6.1–6.8: marketing and Consumer Understanding requirements.
[3]FCA PRIN 12.2.2R–12.2.5R: Products & Services, Price & Value, Consumer Understanding, Consumer Support outcome rules. PRIN 12.4.1R–12.4.3R: cross-cutting rules.
[4]FCA CONC 5A: creditworthiness assessment; CONC 4: pre-contract disclosure; Consumer Credit (Disclosure of Information) Regulations 2010 (SI 2010/1013).
[5]Consumer Credit Act 1974, s.66A: right of withdrawal (14 days). CCA 1974, s.87: default notice. Debt Respite Scheme (Breathing Space Moratorium and Mental Health Crisis Moratorium) (England and Wales) Regulations 2020 (SI 2020/1311).
[6]FCA DISP 1: complaints handling rules — 5-day acknowledgement, 8-week resolution, Financial Ombudsman Service access. FCA FG21/1: vulnerable customers guidance.