Consumer Duty: Are You Evidencing Good Outcomes or Just Hoping for the Best?

Consumer Duty has been in force since July 2023, and the FCA is no longer giving firms the benefit of the doubt. Supervisory visits, thematic reviews, and enforcement activity are all signalling the same message — having a Consumer Duty policy isn't enough. You need to evidence that your firm is consistently delivering good outcomes for retail customers, and that your board is sighted on the data that proves it.

In this episode, we're talking about the Consumer Duty Toolkit — what it contains, why a structured, ready-to-use framework is the most efficient way to embed the Duty properly across your firm, and what the FCA actually expects to see when it comes looking.

What we cover in this episode:

We start with the four outcomes at the heart of Consumer Duty — products and services, price and value, consumer understanding, and consumer support — and why firms that treat these as four separate compliance workstreams consistently struggle to demonstrate the joined-up, outcome-focused thinking the FCA is looking for.

We then look at what genuine embedding looks like in practice — the management information frameworks, the board reporting structures, the customer journey mapping, the complaints and feedback analysis, and the vulnerability identification processes that together give your firm a defensible evidence base.

We discuss the Consumer Duty Annual Board Report — one of the most important documents your firm will produce each year and one that is still being significantly underestimated by many smaller authorised firms. We cover what it needs to contain, how it should be structured, and the common gaps that leave firms exposed.

We also address the ongoing monitoring obligation — because Consumer Duty isn't a one-time implementation project. It's a continuous cycle of outcome testing, data review, and remediation, and firms that haven't built that cycle into their compliance monitoring programme are accumulating regulatory risk with every passing quarter.

Why this matters right now:

The FCA has been explicit that its Consumer Duty supervisory work is moving from implementation assessment to outcomes scrutiny. Firms that were given time to embed the Duty are now expected to demonstrate it is working. The regulator has already written to firms in multiple sectors where its data suggests consumer outcomes are falling short, and formal action is following in cases where firms cannot evidence their position.

The stakes are significant. Consumer Duty failures can trigger requirements to withdraw products, remediate customers, and in serious cases result in public censure or financial penalties. Senior managers with board-level accountability for Consumer Duty outcomes face personal exposure where oversight has been inadequate.

The practical takeaway:

By the end of this episode, you'll have a clear picture of what a robust Consumer Duty framework looks like, where the most common gaps are, and how a structured toolkit can help your firm move from superficial compliance to genuine, evidenced good outcomes.

Our Consumer Duty Toolkit is available to download at complianceconsultant.org — built by qualified regulatory consultants who understand exactly what the FCA expects, and ready to implement across your firm immediately.

Who this episode is for:

Essential listening for compliance officers, MLROs, customer experience leads, product owners, and any senior manager or NED with Consumer Duty accountability at an FCA-authorised firm.

Compliance Consultant — Making Compliance Work.

Visit us at complianceconsultant.org or call us on 0800 689 0190.

References: FCA Consumer Duty — Finalised Guidance FG22/5; FCA Consumer Duty — Annual Review Requirements; PS22/9 A New Consumer Duty — Policy Statement; FCA Consumer Duty Implementation Review, 2024; Financial Services and Markets Act 2023.