Preparing for the annual Consumer Duty board report is a key part of demonstrating how your firm is delivering good customer outcomes and meeting ongoing FCA expectations. The report should not simply be viewed as a compliance exercise. It provides an opportunity for boards and senior management to assess whether products, services, communications, and customer support arrangements are genuinely working in the interests of retail customers.
Firms should ensure that their Consumer Duty annual board report is evidence-based, supported by clear management information, and capable of demonstrating robust governance and effective oversight. The FCA expects firms to show how they are monitoring customer outcomes, identifying foreseeable harm, and taking action where improvements are required. This includes reviewing outcomes across the full customer journey, particularly for vulnerable customers and those experiencing financial difficulty.
When preparing the Consumer Duty board report, firms should also consider whether existing monitoring frameworks remain proportionate and effective in light of changing economic conditions, regulatory expectations, customer behaviours, and emerging risks such as fraud, scams, digital exclusion, and cost of living pressures. A strong report should include evidence of challenge, discussion, and decision-making at board and committee level, rather than being purely descriptive.
Consumer Duty Board Report Checklist
The following Consumer Duty checklist highlights key areas that consumer credit firms should review when preparing their annual board report and assessing compliance with FCA Consumer Duty requirements.
- Review FCA Consumer Duty annual board report expectations and confirm the report timetable, governance process, and board ownership are documented and agreed.
- Reassess whether the firm’s products and services continue to meet the needs, characteristics, and objectives of the identified target market.
- Compile and analyse management information (MI) covering all four Consumer Duty outcomes: Products and services, Price and value, Consumer understanding, and Consumer support.
- Identify and evidence any areas where customer outcomes may be causing foreseeable harm or poor outcomes.
- Review customer complaints data for trends, root causes, recurring issues, and vulnerable customer impacts.
- Analyse FOS complaints, uphold rates, and thematic issues that may indicate conduct or outcome concerns.
- Assess whether customers are receiving fair value, including fees and charges, interest rates, commissions, ancillary products, and arrears and collections practices.
- Revisit fair value assessments and ensure these remain current and evidence-based.
- Review customer communications and journeys to confirm they remain clear, understandable, and support informed decision-making.
- Test key customer communications for readability and comprehension, especially for vulnerable customers.
- Assess whether customer support channels are enabling customers to act in their own interests without unreasonable barriers.
- Review call waiting times, abandonment rates, complaint handling times, and service performance metrics.
- Evaluate outcomes for vulnerable customers and evidence how the firm has adapted support and communications where needed.
- Conduct gap analysis against previous board report findings and confirm remediation actions have been completed or progressed.
- Review product governance arrangements, including distribution strategies and oversight of third parties or appointed representatives.
- Assess whether monitoring and testing frameworks remain sufficiently robust and proportionate.
- Review outcomes testing and quality assurance findings from monitoring, file reviews, and customer journey testing.
- Confirm whether MI is sufficiently granular to identify poor outcomes across different customer cohorts.
- Consider whether there are any emerging risks from cost of living pressures, economic conditions, interest rate changes, digital exclusion, fraud, and scams.
- Ensure senior management challenge and oversight are clearly evidenced in committee and board minutes.
- Review training and competence records to ensure staff understand Consumer Duty obligations and customer outcome expectations.
- Confirm that incentive structures and remuneration arrangements do not drive poor customer outcomes.
- Benchmark customer outcomes against peers, industry data, FCA publications, and relevant thematic reviews where possible.
- Review arrears, forbearance, and collections strategies to ensure customers in financial difficulty are treated fairly.
- Ensure outsourced service providers and key third parties are providing sufficient outcome data and oversight reporting.
- Prepare a concise summary of good outcomes achieved, areas of concern, actions taken, planned improvements, and residual risks.
- Clearly document any identified weaknesses, remediation plans, owners, and target completion dates.
- Ensure the board report includes evidence of challenge, discussion, and decisions rather than being purely descriptive.
- Validate that all MI and conclusions in the report are accurate, traceable, and supported by underlying evidence.
- Consider whether any issues identified may require FCA notification or broader governance escalation.
- Confirm the board can reasonably conclude that the firm is delivering good outcomes for retail customers.
Contact My Compliance Consultant if you need support preparing your Consumer Duty Board Report.
