FCA issued Feedback Statement FS25/2 last month
https://content.govdelivery.com/accounts/UKFCA/bulletins/3c6b0be
You must demonstrate how you’re embedding the Duty: governance, outcome-monitoring, data on vulnerable customers, product/service alignment.
If you’re recommending products you must show they deliver fair value and meet customer needs, especially for vulnerable customers.
It is more than just file checks: you need processes, monitoring and board/senior-management accountability. If you are an RI, you are protected to an extent by following senior management procedures. If this is on BAT, it gives you the guardrails to work from.
It is a DATA DRIVEN REGULATOR. Work smarter, not harder.