The FCA requires firms to provide boards with regular Consumer Duty performance reports demonstrating good customer outcomes. This reporting must include specific evidence showing that monitoring processes work, outcomes meet standards and firms take prompt action when performance deteriorates.
What the FCA Expects from Board Reports
Consumer Duty guidance states that boards must receive sufficient information to assess whether the firm delivers good customer outcomes consistently. Reports cannot rely solely on summary metrics. Boards need evidence demonstrating that monitoring processes are effective and outcomes improve over time.
The regulator expects boards to challenge management when evidence suggests outcomes are deteriorating. This requires board-level visibility into root causes, specific examples and corrective actions, not just high-level percentages.
Firms must document board discussions about consumer outcomes, decisions made and actions directed. This documentation forms part of FCA review evidence when regulators assess Consumer Duty compliance.
Core Evidence Requirements
| Evidence Category | What Boards Need | Why It Matters |
|---|---|---|
| Monitoring coverage | Percentage of interactions reviewed, methods used | Demonstrates oversight is comprehensive |
| Outcome metrics | Customer satisfaction, complaint rates, product performance | Shows actual results customers experience |
| Vulnerability identification | Numbers identified, support provided, outcomes achieved | Proves vulnerable customer protection |
| Dissatisfaction detection | Expressions captured, resolution rates, escalation prevention | Evidence of proactive issue resolution |
| Corrective actions | Problems identified, actions taken, results measured | Shows prompt response to deteriorating outcomes |
Traditional board reporting often provides summary statistics without underlying evidence. Consumer Duty requires boards to understand the quality of information supporting those statistics.
Monitoring Coverage Evidence
Boards must understand what proportion of customer interactions are monitored and whether coverage is sufficient to identify issues reliably.
Sampling approaches that review 1% to 3% of interactions leave boards unable to confirm consistent good outcomes. When asked how they know outcomes are good across all customers, firms relying on small samples cannot provide confident answers.
Complete monitoring evidence shows boards that every interaction is reviewed, all vulnerability indicators are detected and no customer concerns go unnoticed. This comprehensive oversight gives boards confidence in outcome assessments.
One insurance firm’s board questioned management about monitoring adequacy after learning their 2% sampling rate meant 98% of customer interactions received no review. Management implemented 100% AI-powered monitoring to address board concerns.
Customer Outcome Metrics
The FCA expects firms to track specific metrics demonstrating whether customers achieve good outcomes across four Consumer Duty areas.
Products and services meeting customer needs requires evidence that products perform as expected, features match customer requirements and customers understand what they are buying.
Price and value assessment needs data showing customers receive fair value for costs paid, that charges are transparent and that product performance justifies pricing.
Consumer understanding evidence includes comprehension checks, clarity of communications and whether customers can make informed decisions based on information provided.
Consumer support quality requires satisfaction metrics, complaint resolution data and evidence that vulnerable customers receive appropriate assistance.
Boards need granular data for each metric, not just overall averages. Outcomes may be strong for some customer segments whilst weak for others. Aggregate statistics hide these disparities.
Vulnerability Evidence
Consumer Duty requires boards to receive detailed information about vulnerable customer identification and treatment.
The number of vulnerable customers identified across different vulnerability types shows whether detection processes work effectively. Significant changes in identification rates may indicate improved detection or changing customer circumstances.
Support provided to vulnerable customers includes adjusted communications, additional documentation, more time for decisions and ongoing monitoring to verify suitable outcomes.
Outcomes achieved demonstrate whether vulnerable customers receive good results. Higher satisfaction, lower complaints and appropriate product use indicate effective support.
One building society board discovered they had identified only 150 vulnerable customers across 50,000 active clients. After questioning whether detection was adequate, management implemented AI monitoring that identified 1,200 vulnerable customers requiring support.
Dissatisfaction and Complaint Data
Boards must understand not only formal complaint volumes but all expressions of dissatisfaction across customer interactions.
Early dissatisfaction detection shows how many customers express concerns before submitting formal complaints. High detection rates indicate firms identify issues proactively.
Resolution effectiveness measures what percentage of dissatisfaction expressions are resolved without escalating to formal complaints or Ombudsman referrals.
Root cause analysis identifies recurring problems causing dissatisfaction. Boards need this information to direct corrective actions addressing underlying issues rather than symptoms.
Trend analysis shows whether dissatisfaction is increasing or decreasing over time and whether firm actions improve outcomes measurably.
Corrective Action Evidence
When monitoring identifies problems, boards must understand what actions management takes and whether those actions work.
Problem identification describes specific issues discovered through monitoring, the customer segments affected and the potential harm if left unaddressed.
Actions taken include process changes, product modifications, staff training, communication improvements and system enhancements designed to prevent recurring problems.
Results measurement demonstrates whether corrective actions delivered intended improvements. Boards should see evidence that outcomes improved after interventions.
Implementation timelines show boards that management acts promptly when issues emerge. Consumer Duty requires firms to take action as soon as problems are identified, not wait for quarterly reviews.
Real Examples and Case Studies
Generic statistics lack impact. Boards benefit from specific examples illustrating what good and poor outcomes look like in practice.
Positive examples show how processes deliver good outcomes, what vulnerable customer support looks like in action and how early dissatisfaction detection prevents complaints.
Problematic examples demonstrate issues identified, harm prevented and lessons learned. These cases help boards understand risks and assess whether management response was appropriate.
One wealth management firm includes three to five specific customer case studies in each board report. Board members stated these examples provide better understanding than summary statistics alone.
Evidence Quality and Reliability
Boards must assess whether evidence supporting outcomes assessments is reliable and comprehensive.
Data sources should be documented clearly. Evidence from complete AI monitoring of all interactions is more reliable than extrapolated estimates from small manual samples.
Methodology transparency helps boards understand how outcomes are measured, what standards are applied and what limitations exist in measurement approaches.
Independent validation provides confidence that reported outcomes are accurate. Some firms use external auditors or consultants to verify Consumer Duty evidence periodically.
Reporting Frequency
The FCA expects board reporting at least quarterly, with more frequent updates when significant issues emerge.
Quarterly reports provide sufficient frequency for boards to track trends, assess corrective action effectiveness and direct management priorities without overwhelming board agendas.
Ad hoc reporting occurs when monitoring identifies significant problems requiring immediate board attention. Waiting for the next scheduled report may delay necessary corrective action.
Annual deep dives allow comprehensive Consumer Duty assessment including detailed analysis of vulnerable customer treatment, product performance and outcome trends across all business areas.
Board Challenge and Oversight
Consumer Duty requires boards to challenge management actively on consumer outcomes, not simply receive reports passively.
Effective challenge includes questioning whether monitoring coverage is adequate, whether outcome metrics demonstrate good results reliably and whether corrective actions address root causes effectively.
Board minutes should document challenge discussions, management responses and decisions made. These records provide evidence for FCA reviews that boards take Consumer Duty seriously.
One bank’s board challenged management when dissatisfaction metrics showed improvement but formal complaints increased. Investigation revealed detection improvements explained the apparent contradiction. Board challenge led to clearer reporting distinguishing detection rate changes from outcome changes.
Technology Supporting Evidence Gathering
Comprehensive board reporting requires sophisticated data collection and analysis capabilities.
AI-powered monitoring provides complete interaction coverage, consistent assessment against defined standards and real-time identification of issues requiring attention.
Automated reporting systems compile evidence continuously, generate board reports automatically and provide drill-down capability when boards want detailed information about specific metrics.
Audit trail technology documents every customer interaction, assessment performed and action taken, creating comprehensive evidence for both board oversight and FCA reviews.
Common Reporting Gaps
Many firms struggle to provide the evidence boards need for effective Consumer Duty oversight.
Incomplete coverage means boards cannot be confident about outcomes across all customers. Manual sampling creates blind spots that hide problems until they escalate.
Summary metrics without examples leave boards unable to understand what good and poor outcomes look like practically. Statistics require context for effective oversight.
Missing trend analysis prevents boards from assessing whether outcomes are improving or deteriorating over time. Point-in-time snapshots lack the historical context boards need.
Absent root cause information means boards cannot direct effective corrective actions. Knowing complaint numbers increased is less useful than understanding why complaints increased.
Preparing for FCA Reviews
When the FCA reviews Consumer Duty compliance, regulators examine board reporting to assess whether boards exercised effective oversight.
Documentation requirements include board meeting minutes discussing consumer outcomes, management reports provided to boards, evidence supporting reported metrics and board decisions directing corrective actions.
Quality standards expect evidence to be comprehensive, reliable, timely and actionable. Generic presentations with high-level statistics do not meet FCA expectations.
One insurance company faced FCA questions about Consumer Duty board reporting. Their quarterly reports contained summary statistics but lacked supporting evidence. Regulators questioned whether the board had sufficient information to assess outcomes properly. The firm subsequently enhanced reporting with comprehensive evidence.
Benefits Beyond Compliance
Effective Consumer Duty board reporting delivers advantages extending beyond regulatory requirements.
Better decision-making occurs when boards have comprehensive evidence about customer outcomes, enabling informed strategic choices and resource allocation.
Risk identification improves as boards spot emerging problems earlier through detailed monitoring evidence and trend analysis.
Performance management strengthens when boards can assess management effectiveness in delivering consumer outcomes and hold leadership accountable for improvements.
Implementation Requirements
Firms need specific capabilities to provide boards with Consumer Duty evidence meeting FCA expectations.
Comprehensive monitoring infrastructure reviews all customer interactions, identifies outcome issues and tracks corrective action effectiveness.
Data aggregation systems compile evidence from multiple sources including call monitoring, complaint management, product performance and customer satisfaction into coherent board reports.
Reporting automation generates quarterly board reports consistently, provides drill-down detail when boards request it and maintains audit trails documenting evidence provenance.
Frequently Asked Questions
How detailed should board reports be? Reports should provide sufficient evidence for boards to assess outcomes confidently without overwhelming board capacity. Summary metrics with supporting evidence and specific examples typically work well. Boards should have access to detailed data when they want to examine particular issues.
What if our board lacks technical expertise to understand AI monitoring? Reports should explain methodology clearly in non-technical language. Focus on what the monitoring detects and why boards should trust results rather than technical implementation details.
How do we handle commercially sensitive information in board reports? Consumer Duty evidence can be anonymised whilst remaining meaningful. Boards need to understand customer outcomes but do not require personally identifiable information.
Can small firms meet these evidence requirements? Yes. AI-powered monitoring scales to firms of all sizes. Small firms benefit from automated evidence gathering impossible to achieve manually with limited compliance resources.
Learn how comprehensive monitoring provides board-ready Consumer Duty evidence →
