Consumer Duty in 2025 for Equity Release: how to evidence good outcomes (without drowning in manual QA)

Consumer Duty applies in full to open books (since 31 July 2023) and closed products (31 July 2024). The FCA is clear: the Duty is not "once and done"—firms must keep improving and be able to evidence outcomes annually.

Why this matters now

For lifetime mortgage providers, the FCA's current portfolio letter makes Consumer Duty Priority #1 for 2025, calling for stronger MI, culture and governance, with ongoing supervisory scrutiny.

The equity-release lens: why scrutiny is higher

The FCA's multi-firm review of later-life mortgages found standards too often fell short—for example weak consideration of income & expenditure, light discussion of alternatives, and incentives that risk biased advice. The regulator is intervening and expects improvements.

In parallel, the Equity Release Council (ERC) updated its Standards in 2024. Adviser guidance now explicitly calls for assessment (and where needed, verification) of income and expenditure, and for advisers to challenge inconsistencies—plus to document reasons for discounting alternatives.

What the FCA expects you to show

Under PRIN 2A, firms must produce an annual Board Report setting out monitoring of outcomes, actions taken, and whether the firm is complying with the Duty; the Board must review and approve it at least annually. The FCA's 2024 review of first-year reports highlights the importance of:

Report Structure

Clear outcomes-focused structure (all 4 outcomes)
Good-quality MI that actually evidences the conclusions
Analysis of different customer types (including vulnerability)
Visible Board challenge and a concrete action plan

Evidence Requirements

Comprehensive monitoring data
Structured audit trails
Traceable customer outcomes
Board-ready documentation

From sampling to full-population oversight

The Transformation

Old world:

Manual QA on a small sample of calls
Fragmented notes
Anecdotal learning
Limited coverage

Duty world:

Monitor every interaction
Structure the data
Detect risks consistently
Create traceable audit trail your Board can trust

What "good" looks like in practice

Implementation Framework

Transcribe 100% calls/meetings; structure into themes (disclosures, features/risks, alternatives, affordability).
Run rule-based checks mapped to your policy & ERC Standards (e.g., early-repayment charges explained; inheritance impact; alternatives discussed; I&E captured/verified where applicable).
Flag vulnerability cues and record the support route (extra time, family involvement, plain-language follow-ups).
Evidence consumer understanding (teach-back; post-advice confirmations; summary sent and acknowledged).
Generate MI dashboards: outcome rates, exceptions, root-causes, remediation—feeding straight into the Board Report.

Quick checklist: your 2025 Consumer Duty evidence pack

Use this as a contents list for your Board Report annex.

Essential Evidence Components

Outcome coverage: Products & Services, Price & Value, Consumer Understanding, Consumer Support—each with KPIs and trends
Advice quality controls: % interactions monitored; % with all required disclosures; % with alternatives discussed; I&E assessed/verified where relevant; file quality exceptions and fixes
Vulnerability MI: flags, escalations, additional support actions, outcomes vs non-vulnerable cohort
Fair value: methodology, inputs, comparative benchmarks, fee/feature trade-offs; actions taken after reviews
Distribution-chain info sharing: what you get from/ provide to partners; how it informs outcomes monitoring
Board governance: visible challenge (with minutes), agreed actions, owners, timelines; status from prior year

Five pragmatic upgrades to implement this quarter

Mandate I&E capture (and verification where appropriate—e.g., mandatory payment LTMs) in your advice flow; add prompts to challenge inconsistencies.
Swap sampling for full-population monitoring of calls & meetings; use structured checks tied to your policy.
Introduce teach-back and send a plain-English summary (or short personalised video) confirming key points, risks, and next steps.
Build a vulnerability route-of-travel (flag → escalate → evidence) and report differential outcomes.
Industrialise the Board Report: pre-built sections that auto-pull MI, with commentary and action logs aligned to PRIN 2A expectations.

Compliance + CX together (not a trade-off)

Where COSA AI helps:

Comprehensive Coverage

100% interaction coverage: automatic transcription and rule-based checks against your firm policy and ERC Standards, including I&E and essential disclosures
Real-time guardrails: soft alerts in live meetings if something key is missed; vulnerability indicators flagged for human review

Evidence & Reporting

Evidence of understanding: automatic teach-back prompts, post-advice summaries, and optional personalised video landing pages your client (and their family) can rewatch—then logged as proof
Duty-ready MI: dashboards for the four outcomes, exceptions, root causes and remediation—exportable straight into your annual Board Report pack

If you want Consumer Duty to become a competitive advantage—not an admin tax—COSA AI pairs growth with governance across inbound/outbound voice & SMS, live meeting assistance and compliant follow-ups.

FAQs (for advisers & compliance teams)

Do we really need to monitor every interaction?

The FCA doesn't prescribe "100% coverage," but it does expect firms to assess, test, understand and evidence outcomes with good-quality MI and Board challenge. In practice, full-population monitoring is the most robust way to avoid blind spots—especially in later-life lending where risk is higher.

What exactly should the Board sign off?

At least annually, your governing body must review and approve an assessment of outcomes, confirm whether the firm is complying, and agree actions—supported by MI you can provide to the FCA on request.

Are there any sector-specific priorities for 2025?

Yes—Consumer Duty remains priority #1 for lifetime mortgage providers, with emphasis on fair value evidence, vulnerability, closed-book challenges, and robust MI/dashboards to monitor outcomes.

References & further reading

Key Resources

Consumer Duty overview (dates for open/closed books; Board Report requirements; good/poor practice examples)
"Not once and done" speech – continuous improvement and annual Board Report emphasis
Portfolio letter (2025) to lifetime mortgage providers – priorities, MI/dashboards, closed-book challenges
FCA multi-firm review (later-life mortgages) – advice standards, I&E, alternatives, interventions
Equity Release Council Standards (V12, 2024) – adviser guidance on income & expenditure assessment/verification and challenging inconsistencies; adviser checklist

Conclusion

Consumer Duty in 2025 for equity release firms requires a fundamental shift from sampling-based manual QA to comprehensive, AI-powered monitoring that can evidence good outcomes across all customer interactions. The firms that embrace this transformation will not only meet regulatory expectations but also gain competitive advantages through better customer outcomes and operational efficiency.

See COSA AI in action

Book a 20-minute walkthrough to explore full-population call monitoring, live meeting assistance, compliant SMS/voice follow-ups, and personalised video summaries—built to make Consumer Duty evidence painless.