There is a specific rule requirement to disclose any possible disadvantages in the suitability report. The rule (COBS 9.4.7) can be seen here: http://fshandbook.info/FS/html/FCA/COBS/9/4.
Remember that a disadvantage is different to a risk. For example, there is a risk that investments can fall in value, whereas a disadvantage would be that the recommended product has higher charges than the product being replaced.



Consumer Duty – FCA information and help
Shirley McKenzie Compliance FCA, PI, Update
The FCA has added to its published information relating to Consumer Duty to help firms with implementation. The most recent addition to the Consumer Duty webpages is an information for firms page to help firms implement the Duty. This explains more on the areas of the Duty that firms have been raising queries […]