AI Hallucination ResearchAudiencesSectorsUnited KingdomRetail BankingLegalDetail › Finding
Retail Banking × Legal — United Kingdom · updated 2026-05-26 · methodology v2.1
Share / Print Twitter LinkedIn Email

Retail customer definition — charity threshold and sourcebook variation

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005
What the RLB Specialist Panel found

2. Retail customer definition — charity threshold and sourcebook variation

  • Question (paraphrased to protect IP): Does the Consumer Duty apply to micro-enterprises or small charities? Are they 'retail customers' under PRIN 2A?
  • Source regulation: Consumer Duty (PS22/9 + PRIN 2A), Financial Conduct Authority (Regulator portal: https://www.fca.org.uk)
  • What AI assistants typically say: Multiple AI tools gave similar incorrect responses. Both correctly identified that micro-enterprises and small charities fall within the definition of "retail customer" under PRIN 2A, but each introduced a material error: one AI substituted "annual income" for "annual turnover" as the qualifying measure for charities, while another correctly named charities as in-scope but omitted the specific £1 million annual turnover threshold entirely and also failed to note that the definition varies depending on which FCA sourcebook applies.
  • What the regulator actually says: The definition of retail customer includes individual consumers, micro-enterprises, and charities with annual turnover less than £1 million. The definition varies by sourcebook.
  • Why the AI went wrong: "Turnover" and "income" are distinct accounting concepts, and AI tools appear to conflate them — likely because in everyday language they are used loosely as synonyms, even though they carry different meanings in a regulatory context. The omission of the sourcebook-variation qualifier is a separate failure: AI tools tend to present regulatory definitions as uniform when the source rules themselves contain important scope-limiting caveats.
  • Cited source(s):
  • https://handbook.fca.org.uk/handbook/PRIN/2A/1.html — Pretextual
  • https://www.fca.org.uk/publication/finalised-guidance/fg22-5.pdf — Pretextual
  • https://handbook.fca.org.uk/handbook/PRIN/2A/5.html — Pretextual
  • https://handbook.fca.org.uk/handbook/prin2a — Pretextual
Impact for Legal Teams in Retail Banking Sector in United Kingdom working with the AI Hallucinations Affecting Legal at Retail Banking Firms in the United Kingdom

The retail customer definition under PRIN 2A determines whether the Consumer Duty applies to a given counterparty — and an incorrect threshold (annual income rather than annual turnover, or no threshold at all) applied to the charity population could cause a UK Retail Banking firm to either over-scope its Consumer Duty monitoring (adding unnecessary compliance cost) or under-scope it (leaving out-of-scope charities uncovered and creating regulatory exposure).

The omission of the sourcebook-variation qualifier compounds the risk: a firm that treats the PRIN 2A definition as universal across all FCA sourcebooks may apply the wrong standard in product-specific regulatory mapping, and the FCA has made clear that firms are expected to understand their obligations at this level of precision.

References — raw findings (per AI model)
← Previous finding Legal basis of the Consumer Duty — FSMA 2023 disclaimer Next finding → Changes from CP21/36 consultation to PS22/9 final rules
Cite this finding

Each finding has a stable Citation ID (RLB-F-… for aggregated case-study findings, RLB-H-… for raw per-model hallucinations) — like a DOI, the ID always resolves to the canonical finding even if URLs change.

RLB Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005
Plain text Download
RegLeg Specialist Panel (2026). "Retail customer definition — charity threshold and sourcebook variation — Retail Banking × Legal — United Kingdom." Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005. RegLegBrief AI Hallucination Research, published 2026-05-26. https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/
APA 7th edition Download
RegLeg Specialist Panel. (2026). Retail customer definition — charity threshold and sourcebook variation [Hallucination finding RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005]. RegLegBrief AI Hallucination Research. https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/
Bluebook / OSCOLA (US + UK legal) Download
RegLeg Specialist Panel, Retail customer definition — charity threshold and sourcebook variation [RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005], RegLegBrief AI Hallucination Research (May 26, 2026), https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/.
BibTeX Download
@misc{reglegbrief_RLB_F_GB_FCA_CONSUMER_DUTY_PS22_9_Q005,
  author    = {RegLeg Specialist Panel},
  title     = {Retail customer definition — charity threshold and sourcebook variation},
  year      = {2026},
  publisher = {RegLegBrief AI Hallucination Research},
  note      = {Hallucination finding Citation ID: RLB-F-GB-FCA-CONSUMER-DUTY-PS22-9-Q005},
  url       = {https://reglegbrief.com/audiences/sectors/gb/retail_banking/legal/finding/GB-FCA-GB-001-CONSUMER-DUTY-PS22-9-v1-005/}
}
← Back to case study summary Case study detail →