How to Evidence Consumer Duty Outcomes to the Board and the FCA

The Consumer Duty annual board report is now the single most revealing document a retail regulated firm produces about itself. The FCA reads it as a proxy for culture. Boards read it as a proxy for whether the executive actually knows what is happening to customers. Most reports fail both audiences — too long, too defensive, too reliant on process metrics that prove activity rather than outcomes.

Here is how to do it properly.

Start with the outcome, not the framework

The four outcomes — products and services, price and value, consumer understanding, consumer support — are the structure the FCA expects. But the evidence that matters is whether customers, including those with characteristics of vulnerability, are getting good outcomes in practice. That is a different question from whether you have a fair value assessment on file.

For each outcome, ask: what would bad look like in our book, and how would we know? If you cannot answer the second part, you do not have evidence. You have a control.

Distinguish four types of evidence

Boards and supervisors weight these very differently. Be explicit about which you are presenting.

Input evidence - policies, frameworks, fair value assessments, training completion. Necessary but worth little on its own. The FCA has been clear it is not impressed by process artefacts.

Activity evidence - complaints volumes, call handling times, vulnerability flags raised. Useful directionally, easy to manipulate, rarely conclusive.

Outcome evidence - what actually happened to customers. Claims acceptance rates by cohort, persistency, switching behaviour, drawdown patterns versus expectations, outcomes for customers who disclosed vulnerability versus those who did not.

Comparative evidence - how outcomes differ across customer segments, distribution channels, product vintages, or against external benchmarks. This is where genuine insight lives, and where most reports are silent.

A good board pack leads with outcome and comparative evidence. A weak one buries them behind fifty pages of input.

Choose metrics you would defend under cross-examination

The test is not whether a metric is available. It is whether you would stand behind it if the FCA asked why you chose it and what it tells you.

For price and value, distribution of value across customer cohorts matters more than average margin. For consumer understanding, comprehension testing on a sample beats readability scores. For support, abandoned call rates and time-to-resolution for vulnerable customers tell you more than overall NPS.

Where you do not have the data, say so, and say what you are doing about it. Acknowledged gaps with a remediation plan are far stronger than confident-sounding metrics that fall apart on questioning.

Build the negative case

The single most common failure: reports that only present evidence supporting a positive conclusion. Supervisors notice. Boards should.

For every outcome, include the evidence that points the other way. Products with deteriorating value scores. Channels where vulnerable customer outcomes lag. Complaints themes that have not yet moved despite intervention. Then explain what you are doing.

This is the move that separates credible reports from defensive ones. It also protects directors personally — a board that has seen and challenged the difficult evidence is a board that has discharged its duty.

Sequence the board conversation

Do not table the report cold. By the time the board sees it, the executive should have:

1) Walked the chair and SID through the difficult findings privately

2) Aligned with the risk and audit committee chairs on areas of judgement

3) Pre-briefed any non-executive with sector expertise on methodology choices

4) Agreed with the CRO on which findings warrant entry on the risk register

The board meeting should be about challenge and direction, not first-time discovery. If non-executives are learning about a foreseeable harm for the first time in the formal meeting, the process has failed.

What the FCA actually looks for

Based on the supervisory feedback published to date: evidence of genuine challenge, granularity by customer cohort, action taken in response to findings, and consistency between what the board report says and what other MI — complaints data, call recordings, product governance papers — shows. Inconsistency across documents is the fastest route to a Section 166.

The next decision

Before your next reporting cycle, do one thing: take last year's report and ask a sceptical outsider — internal audit, an external adviser, a recently retired NED from another firm — to mark it for outcome evidence versus input evidence. If the ratio is wrong, you have nine to twelve months to fix the underlying data, not the document. Start with the data.