We’ve moved beyond implementation. This is now about evidence, challenge, and outcomes.
After reviewing 180 firms, the FCA found that while progress is being made, too many board reports still fall short where it matters most, demonstrating real impact on customer outcomes.
What good looks like:
- Clear, outcomes-focused reporting (not process-heavy narratives)
- High-quality, decision-useful MI
- Meaningful analysis across different customer groups
- Strong governance and board-level challenge
- A culture that genuinely prioritises good customer outcomes
Where firms are still struggling:
- Data gaps and weak insight
- Limited oversight across distribution chains
- Superficial treatment of vulnerable customers
- Lack of clear, accountable actions
- Board reports that read like compliance exercises, not strategic tools
💡 The direction of travel is clear:
The FCA is no longer asking “Have you implemented Consumer Duty?”
It’s asking “Can you prove it’s working?”
From an MCC perspective, the biggest shift we’re seeing is this:
➡️ The Consumer Duty Board Report is becoming a strategic document, not a regulatory one.
➡️ Firms that treat it as a backward-looking summary will struggle.
➡️ Firms that use it to drive decision-making, challenge, and improvement will stand out.
As we head into the next reporting cycle, the opportunity isn’t just to “comply better” — it’s to use Consumer Duty as a competitive advantage.
The question for Boards now is simple:
Are you reporting on outcomes… or actually driving them?
