Once a year, every firm within the Consumer Duty's scope has to put a question to its board: are we delivering good outcomes for our customers — and how do we know? The quality of the answer depends almost entirely on the evidence behind it. For advice firms, much of that evidence is in client conversations.
What the rules require
Under the governance rules in PRIN 2A.8, a firm must prepare a report for its governing body setting out the results of its monitoring of customer outcomes and any action needed. At least once a year, the governing body must review and approve that report, agree the actions, confirm whether it is satisfied the firm is complying with the Duty, and assess whether the firm's future business strategy is consistent with the Duty. The FCA originally expected firms to appoint a board-level champion for the Duty; since 27 February 2025 it no longer does, although firms can keep the role if they wish. The full framework is set out in our practical guide to the Consumer Duty for advice firms.
The FCA has since published examples of good practice and areas for improvement from firms' board reports, drawn from a sample of 180 firms' first reports, followed by a blog on the second year's reports. Recurring themes are easy to recognise: data presented without explaining what it shows about customer outcomes, too little analysis of how different groups of customers fare, board challenge that isn't documented, and too little evidence of effective action being taken.
A practical structure
- Conclusion first. One paragraph: are customers receiving good outcomes, where aren't they, and what will change?
- Scope and evidence sources. What was monitored and how — including which calls were assessed and which were excluded, and why.
- Outcome by outcome. Products and services, price and value, consumer understanding, consumer support — each with measures, trends and findings.
- Customer groups. How outcomes differ between groups, with customers who have characteristics of vulnerability as a group of their own.
- Root causes and actions. What went wrong, why, who owns the fix and by when. Complaints are one input; our guide to complaints root cause analysis covers finding the cause.
- Progress since last year. Whether last year's actions worked, with evidence.
- Board challenge and approval. The questions the board asked, and its decision.
Call-derived MI for each section
| Section | Call-derived evidence | An example finding |
|---|---|---|
| Scope | In-scope calls assessed; exclusions by reason | "Every fact find and follow-up over two minutes was assessed; 6% of calls were excluded, mostly voicemails." |
| Products & services | Objectives captured; alternatives discussed | "Alternatives were discussed on 93% of fact finds, up from 81% after script changes in Q2." |
| Price & value | Costs, charges and long-term effects explained | "Early repayment charges were the most-missed rule on follow-up calls." |
| Consumer understanding | Key risks covered; understanding checked | "Understanding checks were weakest on calls over 45 minutes." |
| Consumer support | Vulnerability signals, handling and follow-up | "Bereavement was the most common signal; handling improved after targeted coaching." |
| Actions | Most-missed rules, adviser trends, overrides | "Two rules were reworded after frequent reviewer overrides showed they were too strict." |
The example findings are illustrative, to show the kind of statement good MI supports.
For a worked example, how to evidence good outcomes in equity release advice sets out what to evidence on the call for each outcome.
Presenting it so the board can challenge it
- Trends over snapshots. Twelve months of data shows whether things are improving; a single quarter doesn't.
- Definitions up front. What "compliance rate" means, how calls are scoped, and any rule changes during the year.
- Method and limits. How results were produced and checked, including human review of flagged calls and the rate of overrides.
- Evidence on request. Be ready to show the underlying calls, verdicts and quotes behind any headline figure — to the board or to the FCA.
Make the annual report a summary, not a scramble
The firms with the strongest board reports don't assemble them in the last month. They build monthly or quarterly MI around the four outcomes with stable definitions, and the annual assessment summarises it. Our guide to Consumer Duty outcomes monitoring covers the framework behind that MI (defined outcomes, explained tolerances, root causes and action), and compliance MI your board will read covers the dashboard side.
COSA produces this kind of MI from every assessed call — compliance rate by call type and adviser, the most-missed rules, vulnerability flags and coverage with exclusions logged — and exports the evidence behind it. See how it supports the Consumer Duty.
This article is general information, not legal or regulatory advice. Refer to PRIN 2A and FG22/5 for the requirements that apply to your firm.
