Consumer Duty enters its evidence phase: outcomes monitoring becomes the board test

The FCA has drawn a line under the Consumer Duty's implementation phase. In a blog published on 27 July 2026, Charlotte Clark, the regulator's director of cross-cutting policy and strategy, set out what good outcomes monitoring looks like and, more pointedly, what it does not (FCA). The message to boards is that supervisory patience with high-level dashboards and unstructured management information is running out.

The review's central finding is that the strongest firms treat monitoring as an operational discipline, not a reporting exercise. They translate customer outcomes into measurable indicators tied to specific stages of the customer journey, and they can show a clear line from data collected, to decisions taken, to interventions tested (FCA). Weaker firms, by contrast, rely on broad statements and high-level metrics without a structure for identifying poor outcomes or their causes. The distinction matters because it reframes what supervisors will ask for in a section 166 or thematic review: not the framework document, but the evidence trail behind a specific decision to intervene, or not.

The proportionality signal is deliberate

Clark is careful to note that smaller firms produced proportionate examples, identifying a small number of key points where customers were more likely to experience harm and using existing indicators to assess outcomes (FCA). That is a deliberate signal. The FCA is closing off the defence that effective outcomes monitoring requires large teams or complex infrastructure. If a mutual or a mid-sized broker can identify its harm points and act on them, a large bank's inability to do so becomes a governance failure, not a resourcing one. Boards that have accepted higher-cost, lower-clarity monitoring builds should expect questions about why complexity has not produced better identification of foreseeable harm.

The review also lands at a moment when the regulator is actively reshaping the boundary of its supervision. HM Treasury and the FCA held their regulatory perimeter meeting on 30 April 2026, discussing the March update to the Perimeter Report (HM Treasury). Consumer Duty outcomes data is one of the mechanisms by which the FCA identifies where harm is occurring inside its remit, and where authorised firms' distribution chains are pushing risk outside it. Firms whose monitoring cannot distinguish between good and poor outcomes in specific segments are, in effect, ceding that intelligence advantage to the regulator, and to their competitors.

What this changes for senior leaders

Three implications follow. First, the board pack needs to change. Aggregate outcomes metrics that do not link to a decision or an intervention will read, to a supervisor, as evidence of a monitoring framework that is not fit for purpose. Second, second-line functions should be tested on whether they can produce the causal chain the FCA describes: indicator, threshold breached, decision taken, intervention tested, outcome improved. Third, vulnerability and foreseeable harm indicators should be specific enough to trigger action, not broad enough to reassure. The FCA has cited unsuitable applications and financial risk as examples where thresholds are being used effectively (FCA).

The Consumer Duty has moved from a rulebook exercise to an evidence one. Firms that can show their monitoring changes what they do will find supervisory conversations shorter. Those that cannot will find them longer, and more expensive.