How Consumer Duty board reports can drive improved business and regulatory outcomes

Clear articulation of customer outcomes

The strongest reports include dedicated sections for each of the four Consumer Duty outcomes and describe what “good” (and by inference “bad”) looks like in practice. They do not rely on generic statements or assumptions but instead translate regulatory expectations into real-life indicators of customer outcomes. This methodological clarity helps boards to understand and evaluate the evidence in front of them.

Robust, multi‑source evidence

The FCA repeatedly emphasises the importance of high‑quality data. Strong reports incorporate a blend of quantitative MI and qualitative insight. Key inputs include product performance data, complaints analysis, customer feedback, external benchmarking and supporting commentary. This broader evidence base enables boards to scrutinise findings more effectively.

Thoughtful customer segmentation

A common feature of high‑quality reporting is analysis of outcomes across different customer groups. Firms that do this well are able to consider outcomes at the level of individual products/services and the key customer segments they serve, including those with characteristics of vulnerability.

Cross‑functional collaboration and strong governance

Reports with input from multiple business areas tend to be better constructed and more reflective of actual practice. The FCA highlights the benefits of preparing reports over an adequate timeframe, involving appropriate internal challenge, and documenting where the board seeks additional information or clarification (such as through meeting minutes).

A clear cultural narrative

Firms who have a strong cultural alignment with the Consumer Duty expectations tend to produce more impactful reports. The FCA praises reports which demonstrate how leadership behaviours, staff incentives, customer‑focused values and internal training drive behaviours and contribute to decision‑making.

Insufficient or low‑quality data

Lower-quality reports fail to provide robust evidence to support their assertions, relying on generic, high‑level MI with little specificity by product, service or customer group.

Inadequate distribution chain oversight

Many reports lack sufficient detail about how firms are monitoring the impact of their distribution chains on customer outcomes. The FCA expects firms, in line with their role, to gather sufficient information to exercise meaningful oversight of third‑party relationships.

Limited vulnerability analysis

Board report content on vulnerable customers is often limited to a description of a firm’s high-level approach and fails to analyse the quality of the outcomes being delivered.

Unclear or non‑specific action plans

Many action plans lack operational rigour by failing to include sufficient information on timelines, prioritisation, accountability, and next steps.

Strengthened MI

Firms should ensure their data evidence how they’re meeting the Duty’s outcomes, including:

• checking data is accurate and reliable

• identifying and looking to fill key data gaps

• defining what ‘good’ and ‘bad’ looks like for each of the Duty’s four outcome areas

• demonstrating, through data and MI, effective oversight of the distribution chain, including clear roles and controls, identified and escalated risks to customer outcomes, and timely remediation influenced across third parties

Enhanced customer segmentation

Firms should use customer segmentation to assess whether the Duty’s outcomes are being delivered across different customer groups, including:

• refreshing and expanding segmentation where necessary

• assessing how outcomes differ across key customer types and products

• identifying and analysing outcomes for customers with characteristics of vulnerability

• using segmentation insights to inform targeted improvements to products, services and communications

Structured and collaborative drafting process

Firms should ensure the drafting process for the board report is appropriately structured and governed, including:

• engaging relevant teams and subject‑matter experts at an early stage

• gathering and maintaining evidence on an ongoing basis, rather than retrospectively

• allowing sufficient time for internal challenge, review and board‑level governance

• clearly documenting key judgements, issues and areas requiring further oversight

Clear, measurable action plan

Firms should be able to evidence a clear and effective action plan through the board report, including:

• defining clear, specific and measurable actions linked to identified risks or weaknesses

• assigning ownership and timeframes to support effective oversight and accountability

• explaining how progress will be monitored and revisited as part of the next annual reporting cycle