Product Governance & Distribution
Product oversight and governance support across PROD, target market definition, fair value, distribution strategy and manufacturer and distributor responsibilities.
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What we do
Product governance is where Consumer Duty, distribution and commercial strategy meet. PROD allocates obligations by role rather than by firm type, which is why so many firms are unclear whether they are acting as manufacturer, co-manufacturer or distributor for a given product.
The FCA has repeatedly found that product approval processes exist on paper but do not constrain what the business does in practice. Target markets are described so broadly that they exclude no one, distribution strategies do not reflect actual distribution, and product reviews are triggered by the calendar rather than by outcome data.
We review and rebuild product governance so that responsibilities are properly allocated, target markets are meaningful, fair value assessments are evidenced and distribution controls prevent products reaching customers they were not designed for.
Role Determination
We establish whether the firm is manufacturer, co-manufacturer or distributor for each product and document the basis.
Framework Review
We test the product approval process, target market definitions and fair value evidence against PROD and the Duty.
Distribution Controls
We review distribution strategy, information exchange and oversight of the distribution chain.
Monitoring & Review
We design product review triggers and monitoring based on outcome data rather than fixed cycles.
What's Included
Manufacturer / Distributor Analysis
Documented role allocation across the product range, including co-manufacturer arrangements.
Product Approval Framework
A process with genuine decision points, evidence requirements and sign-off authority.
Target Market Statements
Meaningful positive and negative target market definitions linked to distribution strategy.
Fair Value Assessments
Assessment methodology covering distribution chain costs, benefits and differential outcomes.
Product Information Exchange
Defined data flows between manufacturers and distributors, in both directions.
Product Review & Monitoring
Trigger-based review, outcome monitoring and escalation where products underperform.
Who this service is for
Firm types
- - MGAs and insurance manufacturers
- - Insurance brokers and distributors
- - Investment product manufacturers and platforms
- - Consumer credit and mortgage product providers
Situations & Triggers
- - Manufacturer and distributor responsibilities are unclear
- - Target markets are too broad to constrain distribution
- - Fair value evidence relies on assertion
- - Products are reaching customers outside the target market
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
PROD 4 Compliance for MGAs in 2026: What the FCA Expects
PROD 4 compliance for an MGA starts with its actual role in each product. Manufacturer status brings product approval, target market, fair value and review duties, and the rules changed in December 2025 and June 2026.
How to Conduct an Insurance Fair Value Assessment in 2026: Evidence, Data and Governance
An insurance fair value assessment asks whether the total price the customer pays bears a reasonable relationship to the quality of the cover and service. PROD 4 requires the evidence, the governance and action where value fails.
ASIC Online Broker Review 2026: DDO, Onboarding and High-Risk Investment Compliance
ASIC's 2026 surveillance of online brokers found weaknesses in target market determinations, onboarding controls and fractional-share disclosures across nine entities.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
A firm is generally a manufacturer where it has a decision-making role in designing or developing a product, or in significantly adapting an existing product. Where two firms share those decisions, such as an insurer and an MGA, co-manufacturer arrangements apply and the allocation of responsibilities should be recorded in a written agreement.
It must be granular enough to influence distribution. That means identifying the customer needs, characteristics and objectives the product is designed for, defining the negative target market, and linking the definition to a distribution strategy that is actually capable of reaching the intended customers and not others.
They overlap heavily. The products and services outcome and the price and value outcome under PRIN 2A build on PROD obligations, and firms are expected to operate a single coherent framework rather than two parallel processes. Fair value assessment is the clearest point of overlap.
Manufacturers must provide distributors with adequate information about the product, target market, fair value assessment and distribution strategy. Distributors must provide manufacturers with sales and outcome information sufficient for the manufacturer to review whether the product remains consistent with the target market and continues to deliver fair value.
At regular intervals appropriate to the product, and additionally whenever an event occurs that could materially affect the target market or customer outcomes. Reviews driven only by an annual cycle typically miss emerging harm.
Yes. We test the framework against PROD and the Duty, sample recent product approvals and reviews, assess whether the process constrains commercial decisions in practice and provide a prioritised remediation plan.