TL;DR: The Consumer Duty sets four retail customer outcomes under Principle 12 and PRIN 2A: products and services (PRIN 2A.3), price and value (PRIN 2A.4), consumer understanding (PRIN 2A.5), and consumer support (PRIN 2A.6). Each outcome needs its own evidence trail. The FCA’s first two implementation years tested whether firms wrote the policies. Its 2026 reviews test whether firms can prove customers receive good outcomes consistently, across the whole book, not a sample. In its 16 April 2026 review of Year 2 board reports, the FCA told firms to move past management information dashboards to analysis that draws conclusions, to document Board challenge, to monitor outcomes delivered through distribution chains, and to deepen the evidence on consumer understanding and support. Its 13 March 2026 consumer understanding review found that sales data and the absence of complaints do not prove customers understood anything. The firms best placed to evidence all four outcomes monitor every interaction, map each finding to a specific outcome, collect evidence close to the interaction, and connect each issue to the action taken.
The Consumer Duty came into force for open products in July 2023 and for closed products in July 2024. The implementation phase is over. The FCA now runs active, thematic supervision, and the question it puts to firms has changed. It no longer asks whether you hold a Consumer Duty policy. It asks whether you can prove your customers receive good outcomes, consistently, across all four areas, and whether your board can see how you know.
This article explains the four outcomes, what the FCA expects firms to evidence for each, where firms most often fall short, and what the regulator’s 2026 publications have added to the standard.
For a full overview of Consumer Duty evidence requirements, see our Consumer Duty compliance guide →
What are the four Consumer Duty outcomes?
The four outcomes define the areas where firms must demonstrate that retail customers receive good results. They sit beneath Principle 12 and the Duty’s cross-cutting rules, which require firms to act in good faith, avoid foreseeable harm, and support customers in pursuing their financial objectives.
The four outcomes cover the parts of the customer journey where a firm shapes what the customer experiences:
- Products and Services (PRIN 2A.3). Products are designed for a clearly defined target market and distributed through appropriate channels.
- Price and Value (PRIN 2A.4). The price a customer pays bears a reasonable relationship to the overall benefits they receive.
- Consumer Understanding (PRIN 2A.5). Communications equip customers to make effective, timely, and properly informed decisions.
- Consumer Support (PRIN 2A.6). Customers can use products and get help throughout the relationship without unreasonable barriers.
The FCA expects firms to monitor and evidence outcomes across all four. Writing the policies and leaving the outcomes unmeasured does not meet the standard.
What changed in 2026
Three FCA publications since the start of 2026 raised the evidential bar, and every firm reviewing its approach should read them as a set.
On 16 April 2026, the FCA published its observations on the first two years of Consumer Duty board reports. The strongest reports drew on a wider range of quantitative and qualitative data, including trend analysis, root cause assessment, and comparisons across customer groups. The FCA also named four areas for improvement that bear directly on evidence. Firms presented extensive data without explaining how it demonstrated good or poor outcomes, so the FCA told them to push past management information dashboards to analysis that draws conclusions and challenges the firm’s own practices. Monitoring of outcomes in distribution chains was often weak where firms relied on intermediaries or outsourcing partners. Most boards approved the reports, but many did not document the challenge they gave, which makes it hard to see how senior leaders tested the evidence. And some reports leaned heavily on products, services, and value while underweighting consumer understanding and support.
On 13 March 2026, the FCA published the findings of its review into consumer understanding. Good practice meant analysing insight from call listening, complaints, chat transcripts, website analytics, drop-off data, and surveys, then testing communications with real customers before and after changes. The recurring weakness: several firms relied on sales data or the absence of complaints as evidence that customers understood their products, which the FCA said provides no reliable assurance whatever the firm’s size.
Across 2025 and into 2026, the FCA confirmed that distribution-chain accountability is a live consultation area, with proposals on where the Duty applies expected in the first half of 2026. The April board-report findings already flagged distribution-chain monitoring as weak, so firms that rely on third parties to reach customers should expect closer scrutiny of how they evidence outcomes beyond their own front door.
The throughline across all three is consistent. The FCA has moved from “show us the policy” to “show us the proof, across the whole book, and show us your board tested it.”
Products and Services outcome (PRIN 2A.3)
What the FCA expects
Firms must design and distribute products that serve the needs of a defined target market. Firms need to show that they have defined the target market for each product, considered how the product meets that market’s needs and objectives, chosen distribution channels that reach the intended audience, and monitored performance after launch.
Product governance does not end at launch. Firms must keep assessing whether a product delivers value over time and whether it still reaches the customers it was built for. A target market defined as broadly as “anyone who wants a pension” gives no meaningful filter on distribution and is unlikely to meet the standard.
Where firms commonly fall short
Product design documentation is usually thorough, and approval governance is often strong. Problems surface after launch. Boards review the product at the design stage but hold little data on how it performs once customers use it. Monitoring leans on high-level indicators such as sales volumes or complaint rates rather than outcome data. Where products reach customers through third-party distribution, firms often cannot show the product is reaching the right people, which is exactly the weakness the FCA flagged in its April 2026 review of distribution-chain monitoring.
What good evidence looks like
- Customer outcome data linked to specific products
- Periodic product reviews supported by data, covering whether actual outcomes still match target market intent
- Governance records that show challenge and decision-making
- Monitoring that confirms products reach the intended target market, including through any third-party distribution
Evidence should show how the product was designed and how it performs across the customer base over time.
Price and Value outcome (PRIN 2A.4)
What the FCA expects
Firms must demonstrate that customers receive fair value, meaning the price paid bears a reasonable relationship to the overall benefits, financial and non-financial. A fair value assessment typically covers the nature and quality of the product, any limitations on scope, the expected total price across the full relationship, comparable offerings, and whether any group of customers subsidises another.
The FCA’s review of fair value frameworks set a clear marker: profit margins should feature in the assessment. Firms that benchmark price against competitors only, without reference to their own margins, may not meet the standard. The level of documentation is proportionate to the size of the firm and the complexity of the product, so a small advice firm is not expected to produce a consolidator’s volume of evidence, but the assessment must still exist and stand up to scrutiny.
Where firms commonly fall short
Many firms ran value assessments during initial implementation and never revisited them. Pricing structures stay fixed while customer outcomes move. Assessments lean on pricing methodology rather than customer data, so a model that looks logical on paper cannot show customers receive fair value in practice. A single generalised template gets stretched across products with very different characteristics. Margins go unmentioned. Non-financial costs, such as the time and effort a customer spends to amend or cancel, get ignored. Governance records show approval without documented challenge.
What good evidence looks like
- Documented value assessments for each product or service, supported by customer outcome data and cost data
- Margin analysis, not competitor benchmarking alone
- Benchmarking against comparable products with a documented method
- Periodic reassessment as pricing or product structures change
- Governance records that show oversight and challenge
- MI segmented by customer group, including customers in vulnerable circumstances, to show whether value differs across the book
Consumer Understanding outcome (PRIN 2A.5)
What the FCA expects
Firms must communicate so that customers can make effective, timely, and properly informed decisions. Every communication should meet the information needs of retail customers, be likely to be understood by them, and equip them to act. Providing the information is not enough. Firms must consider, and show, whether customers are likely to understand it.
The FCA’s 13 March 2026 consumer understanding review set out what good looks like. Firms analyse insight from multiple sources, including call listening, complaints, chat transcripts, website analytics, drop-off data, and surveys. They test communications with real customers before and after changes, using surveys, comprehension checks, A/B testing, and callbacks, and they document what changed, why, and the effect. The review highlighted firms that set comprehension targets, in one case at least 80% correct recall of key points, and redrafted communications until they hit the target.
Where firms commonly fall short
Firms invest in well-written documents, then hold little evidence that customers understood them. The FCA found firms relying on sales data or the absence of complaints as proof of understanding, which provides no reliable assurance. Testing is often superficial, one-off, or poorly documented. Communications get updated without a record of testing or evaluation. Firms make surface changes, shorter wording, new icons, colour tweaks, without improving the clarity or prominence of key information. And many firms do not test with customers who have accessibility needs, language requirements, or lower financial capability, so they cannot show the communication works for those groups.
A common weakness is the absence of interaction monitoring. When a customer speaks to an adviser or contacts support, confusion shows up in the conversation through repeated questions, hesitation, or misunderstanding. Without monitoring those interactions, a firm cannot see where understanding breaks down.
What good evidence looks like
- Monitoring data from real customer interactions, including call and chat review
- Records of communication testing with representative customers, including before-and-after results
- Comprehension MI segmented by customer group, including customers in vulnerable circumstances
- Readability reviews for key documents
- Governance records showing regular review of scripts, standard letters, and guidance, with the decisions taken
Interaction monitoring carries particular weight because it shows how customers respond in real conversations rather than how a document reads on the page.
For more on the consistency problems that appear when monitoring relies on manual QA samples, see the evidence coverage section in our Consumer Duty guide →
Consumer Support outcome (PRIN 2A.6)
What the FCA expects
Firms must design ongoing service so customers can get the help they need throughout the relationship without unreasonable barriers, including customers in vulnerable circumstances. Evidence should show that customers can reach the firm through appropriate channels, that requests are handled promptly, that escalation paths exist and get used, and that vulnerable customers receive appropriate support.
The FCA uses the term “sludge practices” for friction introduced into customer journeys, such as cancellation that is materially harder than sign-up, or complaint handling that wears customers down rather than resolving their issue. Good practice involves mapping the customer journey to find and remove friction before customers hit it, with the changes documented and tracked.
Where firms commonly fall short
Support is where Consumer Duty problems often surface first, because complaints and service friction collect here before they show up elsewhere. Many firms track complaint volumes and response times, but those metrics rarely reveal the interaction that produced the complaint. When monitoring focuses only on formal complaints, firms miss the earlier signals that customers are struggling. Acquisition journeys are smooth while cancellation journeys are not. And processes sometimes make customers fear a worse level of service if they disclose a vulnerability, which suppresses the very disclosure the firm needs to provide support.
What good evidence looks like
- Response time and resolution data, including end-to-end completion times across channels
- Interaction monitoring showing how advisers and agents handle customer concerns
- Customer journey maps covering onboarding, ongoing service, and exit
- Records of vulnerability identification and the support actions taken, without creating further barriers
- Complaint data with root cause analysis and the changes made as a result
- Documentation of escalation paths and their use
Outcome data following a support interaction also shows whether the issue was actually resolved.
Consumer support pressure is especially visible in protection insurance advice, where vulnerable customers and complex products meet. See our detailed analysis of Consumer Duty in protection insurance →
Why evidencing all four outcomes at once is the real challenge
The four outcomes do not operate in isolation. A single advice conversation can touch all of them. An adviser explains product features, discusses price, checks the customer’s understanding, and answers questions about support or claims. Each element maps to a different outcome.
That creates a structural problem for monitoring. Many firms still run manual QA that reviews a small percentage of interactions, often assesses one outcome at a time, and covers only a slice of the customer base. When two or three percent of interactions are reviewed, a firm cannot show that good outcomes occur consistently across all four areas for everyone else. This is why coverage has become central to Consumer Duty evidence, and why the FCA’s April 2026 finding, that firms must go beyond MI dashboards to analysis that draws conclusions across customer groups, lands so directly on sampling-based models.
For a deeper discussion of the risks attached to small sample sizes, see our analysis of sampling under Consumer Duty →
What a credible four-outcome evidence framework looks like
Coverage across all interactions, not a sample
Many firms review between two and five percent of interactions through quality assurance. Sampling gives useful insight, but it does not demonstrate outcomes across the whole customer base. The FCA has made clear that assumptions about the interactions a firm did not review are not evidence. Firms need visibility into how interactions unfold across the organisation.
Aveni Detect was built for this. It reviews 100% of customer interactions rather than a manual sample, which is what lets a firm evidence outcomes across the whole book instead of inferring them from a fraction of it. In practice this has supported an 82:1 AI-to-human review ratio and the analysis of more than 1.4 million customer conversations, with over 1 million automated QA assessments completed.
Outcome-specific assessment criteria
Evidence must map directly to each of the four outcomes. Generic management information and complaint statistics rarely suffice on their own. Firms need defined assessment criteria that connect to product suitability, value, understanding, and support, applied consistently and reviewed periodically. The FCA’s April 2026 finding, that firms presented data without explaining what it showed about outcomes, is precisely the failure that outcome-specific criteria prevent.
Timeliness: evidence collected close to the interaction
Retrospective sampling often surfaces issues months after the interaction, by which point harm may already have happened. The FCA expects firms to monitor outcomes in a timely way so emerging issues get addressed quickly. Evidence collected close to the interaction gives a clearer view of the customer’s experience.
Audit trails that connect evidence to action
The FCA expects firms to show what they found and what they did about it, and its April 2026 review asked boards to document the challenge they gave. An evidence framework should connect identified issues, the remedial action taken, and the governance oversight of that action, with board papers and minutes that record the questions asked and the follow-ups requested. Maintaining those records is what lets a firm show how outcomes are monitored and improved over time.
For a full explanation of how these elements fit together, see the Consumer Duty compliance guide →
Monitoring and MI: how to evidence each outcome
| Outcome | Example MI and evidence sources | Example board reporting focus |
|---|---|---|
| Products and services (PRIN 2A.3) | Complaints data, persistency, customer feedback, distribution-channel monitoring, post-launch outcome data | Product review findings, actions taken, distribution-chain outcomes |
| Price and value (PRIN 2A.4) | Fair value assessments, margin analysis, cost data, customer-group outcome data, benchmarking | Fair value conclusions, differential outcomes across customer groups |
| Consumer understanding (PRIN 2A.5) | Call and chat review, drop-off data, comprehension testing results, readability reviews | Communication review decisions, comprehension results by customer group, changes made |
| Consumer support (PRIN 2A.6) | Journey completion rates, complaint resolution times, channel access data, vulnerability records | Friction points found and removed, vulnerable customer support outcomes |
The FCA expects MI granular enough to show whether outcomes differ by customer group, product, or channel. Aggregate data that hides poor outcomes for a specific segment may not satisfy the standard, and boards should receive outcome-focused analysis rather than raw dashboards.
Where to start with Consumer Duty outcome monitoring
Most firms already collect a great deal of information about their operations. The question is whether that information actually demonstrates good customer outcomes. A practical starting point has three steps.
First, map the evidence you currently hold against each of the four outcomes and find where it is thin. Second, check whether your monitoring covers the full range of customer interactions or rests mainly on sampling. Third, review your board reporting to see whether it includes outcome-specific analysis, documents the challenge the board gave, and covers consumer understanding and support as fully as products and value, or whether it repackages existing management information.
These steps usually show where additional monitoring or governance is needed.
For a complete overview of Consumer Duty evidence requirements and an implementation roadmap, see the full Consumer Duty compliance guide →
Frequently asked questions about the Consumer Duty outcomes
What are the four Consumer Duty outcomes?
The four outcomes are products and services (PRIN 2A.3), price and value (PRIN 2A.4), consumer understanding (PRIN 2A.5), and consumer support (PRIN 2A.6). Each requires firms to evidence that retail customers receive good outcomes in that specific part of their relationship with the firm.
When did the four Consumer Duty outcomes come into force?
The Consumer Duty, including all four outcomes, came into force for open products and services in July 2023, and for closed products and services in July 2024.
What did the FCA’s 2026 reviews add to the four outcomes?
The outcomes themselves did not change. The evidential expectation did. In its 16 April 2026 review of Year 2 board reports, the FCA told firms to move past MI dashboards to analysis that draws conclusions, document the challenge boards give, monitor outcomes delivered through distribution chains, and deepen the evidence on consumer understanding and support. Its 13 March 2026 consumer understanding review found that sales data and the absence of complaints do not prove customers understood their products.
What is the difference between the four outcomes and the cross-cutting rules?
The cross-cutting rules describe how firms should behave: act in good faith, avoid foreseeable harm, and support customers in pursuing their financial objectives. The four outcomes cover the specific parts of the customer journey where those principles must be demonstrated in practice.
Do the four Consumer Duty outcomes apply to closed products?
Yes. The FCA expects firms to consider how the Duty applies to closed products as well as open ones. Monitoring may differ with the nature of the product, but firms must still consider whether customers continue to receive fair outcomes.
What does a fair value assessment need to include for the price and value outcome?
A fair value assessment should cover the nature and quality of the product or service, any limitations on scope, and the expected total price across the full relationship. The FCA expects assessments to reference the firm’s own profit margins, not competitor benchmarks alone, with documentation proportionate to the firm’s size and the product’s complexity.
How often should firms review their Consumer Duty outcome monitoring?
Monitoring should be ongoing rather than periodic. Firms typically review outcome data regularly and report key findings to senior management and the board at least annually as part of governance.
What does the FCA consider inadequate evidence for the Consumer Duty outcomes?
Evidence is usually inadequate when it rests only on policies, historic documentation, or small samples of interactions, or when it presents data without explaining what it shows about customer outcomes. For consumer understanding specifically, the FCA has said that sales data and the absence of complaints do not prove customers understood the information.
What happens if a firm cannot evidence the Consumer Duty outcomes?
Firms that cannot evidence the outcomes face supervisory intervention before any formal enforcement outcome. Binding requirements, skilled person reviews, and compelled remediation can all be deployed at the investigation stage, and the operational and reputational impact can be significant.
For a practical checklist that helps identify where evidence is missing, see our Consumer Duty compliance checklist →
Key terms
Consumer Duty: The FCA’s conduct standard, in force since July 2023, requiring firms to deliver good outcomes for retail customers across four defined areas under Principle 12 and PRIN 2A. It is outcomes-focused rather than prescriptive.
Fair value assessment: A documented analysis showing that the price a customer pays bears a reasonable relationship to the overall benefits they receive. The FCA expects these assessments to reference the firm’s own profit margins, not competitor benchmarks alone.
Target market: The specific group of customers a product or service is designed and distributed to serve. The FCA expects target market definitions precise enough to provide a meaningful filter on distribution, not a broad demographic category.
Sludge practices: Friction introduced into customer journeys that makes it harder for customers to act in their own interests, such as cancellation that is materially harder than sign-up, or complaint handling that discourages resolution.
Management information (MI): The data and reporting firms use to monitor whether customers receive good outcomes across all four areas. The FCA expects MI granular enough to show whether outcomes differ by customer group, product, or channel, with findings reported to the board at least annually and accompanied by analysis that draws conclusions.
Coverage: The proportion of customer interactions a firm reviews when monitoring outcomes. Sampling a small percentage gives insight but does not demonstrate outcomes across the whole customer base, which is why coverage has become central to Consumer Duty evidence.
Aveni Detect reviews 100% of customer interactions and maps the evidence to each of the four Consumer Duty outcomes, so firms can show good outcomes across the whole customer base rather than inferring them from a sample. To see how it handles the evidence layer across your interactions, book a demo.
