With the FCA’s Consumer Duty framework now fully in effect, regulated firms must complete and review an annual Consumer Duty board report by 31st July. This report is critical in demonstrating how a firm delivers good outcomes for retail customers an essential requirement of the Duty.
At My Compliance Consultant, we support firms across the UK in preparing high-quality, compliant board reports that satisfy regulatory expectations. Below, we outline the key elements your report should include.
Core Components of the Report
Assessment of Customer Outcomes
Your report should clearly assess whether your firm’s products and services are delivering good outcomes. Include both positive outcomes and any evidence of poor outcomes, supported by root cause analysis. This shows that your firm is not only monitoring results but actively learning and improving.
Monitoring and Data Analysis
Provide relevant management information (MI) that supports your assessment. The data must be high quality, well interpreted, and demonstrate how outcomes vary across customer groups including vulnerable customers. Use charts, dashboards, or scorecards to support your analysis and provide a clear audit trail.
Actions Taken
Highlight what actions your firm has taken to address risks or poor outcomes identified during the year. Be specific include timelines, responsible owners and the criteria used to measure success. This shows that the board is taking real, outcome-driven action.
Future Business Strategy
Explain how your business strategy supports good customer outcomes. If adjustments are needed to meet your Consumer Duty obligations, these must be clearly set out and agreed by the board.
Governance and Oversight
Board Review and Approval
The governing body must formally review and approve the Consumer Duty report annually. This includes confirming that the firm is complying with the Duty and endorsing any proposed improvements.
Board Challenge and Scrutiny
Regulators expect evidence of meaningful board engagement not just passive approval. Include board meeting minutes or follow-up actions that show directors have challenged assumptions and contributed to decisions.
Cross-Functional Input
Your report should reflect insights from across your firm not just the compliance team. Involve departments like customer service, risk, product development, and distribution to demonstrate collective ownership of customer outcomes.
Culture and Customer Focus
Consumer Duty Champion
Document the role of your board-level Consumer Duty Champion, including how they’ve influenced governance, culture, and firm-wide engagement with the Duty.
Focus on Vulnerable Customers
Explain how your firm identifies, supports, and monitors customers with characteristics of vulnerability. You must show how their outcomes are tracked distinctly and any measures taken to ensure fair treatment.
Distribution Chain Oversight
Include details of how your firm collaborates with third parties (e.g., introducers, brokers, platforms) to ensure good outcomes throughout the entire customer journey. Evidence of data sharing and joint oversight is especially important.
Final Thoughts
The annual Consumer Duty board report is a vital opportunity to demonstrate your firm’s commitment to transparency, fairness, and outcome-driven practices. By ensuring the report is comprehensive, evidence-based, and board-approved, you not only meet your FCA compliance obligations, but also enhance trust with customers, partners, and regulators.
Need support drafting or reviewing your Consumer Duty report? Contact My Compliance Consultant today and ensure your board submission meets all FCA expectations on time and in full.