Skip to main content

Preparing the Consumer Duty Board Report

Who this blog is for:


Board members, senior executives, Consumer Duty champions, and those leading the implementation, monitoring, and reporting of the Duty.

At a glance


  • Firms subject to the Duty should already be gathering the data needed to prepare their first Duty Board report. Time is of the essence, as the full extent of data gaps and other issues will only emerge as firms start to compile their first report.
  • The report should include three key elements: evidence of customer outcome monitoring, resulting actions (including improvements), and changes to the business strategy.
  • In this article we include a question bank for Board members and key personnel involved in Duty compliance to inform their preparation, review, and challenge of the Duty Board report. These key questions touch on the definition of good outcomes, granularity of reporting, data quality, completeness and interpretation, comparison of outcomes between distinct groups of customers, root cause analysis of poor outcomes and actions taken to address issues/areas for improvement.
  • The Duty Board report will require intense collaboration by different stakeholders across the organisation. Firms need to ensure that they set out a clear allocation of roles and responsibilities, robust communication channels and a plan of action to produce the report by July 2024.



One of the cornerstones of the Duty is the annual requirement for the Board to review and approve the firm’s report on retail customer outcomes, confirm the firm is complying with its Duty obligations, and that its business strategy is consistent with Duty principles (the ‘report’).

The first report is due before 31 July 2024. It is crucial that risk owners and Board members consider the evidence and data required for its preparation. Firms should expect the FCA to scrutinise the report and, in some cases, request the underlying evidence to support conclusions and actions being taken.

In this article, we outline the essential elements of the report as required by the FCA’s rules and guidance, suggest key questions for Board members to ask, and outline core stakeholders and their roles in preparing the report.

The report: key content


Under the Duty rules1 firms need to prepare a report for their Board setting out the results and actions of monitoring retail customer outcomes. The Board is then required to:

  • review and approve the firm’s report on customer outcomes;
  • confirm it is satisfied that the firm is complying with the Duty2; and
  • assess whether the firm’s future business strategy complies with the Duty obligations.

Boards approving the firm’s report on customer outcomes should also agree on the actions to address weaknesses and areas of non-compliance with the Duty and any changes to the firm’s business strategy necessary to ensure continued compliance with the Duty.

A sufficiently detailed and well evidenced report should allow the Board to confirm it is satisfied that the firm is in compliance with the Duty.

The above can be reflected in three core pillars of the report:

A. Monitoring results: the report should include overall monitoring results, including those that indicate poor outcomes and/or any groups of customers that are receiving worse outcomes compared to other groups, together with an evaluation of the impact and root cause of those findings.

B. Actions taken to address risks or breaches or improve outcomes: firms need to act where they identify poor outcomes or where better outcomes could be achieved by specific customer groups. Examples include: products taken off the market, changes to product features, pricing structures or fees, changes to distribution arrangements and distributor on-boarding controls and practices, changes to customer journeys and support provision or communications.

C. Business strategy impact: firms need to assess whether their current and future business strategy align with the Duty and, if they do not, make the necessary changes. Examples of business strategy impact include: changes to sales strategies such as a reduction in reliance on low/poor value products in future, embedding Duty compliance in the process of deciding who to partner with and the level of scrutiny over third parties, and robust consideration of the impact of cost-cutting exercises on customer support levels.

Reviewing the report: question bank


This question bank is intended to aid those preparing, challenging and reviewing the report. This includes Board members, risk committee members, Consumer Duty steering group members, the Duty champion and other executives conducting deep dives into the firm’s Duty implementation and compliance.

We have categorised the questions by theme across the three content areas of the report and indicate both key (in bold) and supplemental questions for each area.

Monitoring Results

Key and supplementary questions

Defining good outcomes:
key decisions around what constitutes ‘good’ outcomes should be underpinned by evidence and robust governance.
  • Has the firm identified key risks to and metrics to indicate good customer outcomes across each of the four Duty outcomes (product, price, understanding and support)?
  • What is the evidence to justify that certain metrics and ranges represent good outcomes?
  • How does the firm ensure timely reporting of issues where outcomes could be deteriorating for customers?
  • Do key stakeholders understand the level of assurance provided by the key data/metrics? For example, is there an understanding of the coverage and sample size of customer outcome testing across the firm?

Level of granularity:
a key challenge for many firms is how to distil the 100s of metrics currently in use into those that demonstrate good customer outcomes.
  • Does the report disclose information at a level which enables the Board to understand the quality of outcomes for individual products, product types or product classes?
  • How granular is the data with regards to specific customer groups (eg. vulnerable customers or specific cohorts by age, ethnicity, gender)?
  • Has an assessment of the key required metrics taken place to avoid a volume only approach / filter relevant metrics?

Data quality and completeness: ensuring the data used in making decisions is of high quality is central to the reliability and quality of the Duty framework output and should include controls and standards over third-party data.

  • Are there any data gaps or weaknesses that the Board should be aware of?
  • If there are, what is the plan to address them and what is their impact on demonstrating overall Duty compliance?
  • Does the firm have a data strategy to control data quality and completeness? Is this taken into consideration in decision making, for example to give more evidential weight to higher quality/more complete data?
  • Is the firm confident in the quality and completeness of data provided by third parties?
  • Does the firm need to make data provision part of its third parties’ contractual responsibilities?
  • How is the firm dealing with contradictory data?
  • Is there a process to guide the Board through data interpretation to avoid bias?

Sales and marketing data:
the FCA expects firms to consider using all available data sets to monitor customer outcomes, including data that traditionally does not form part of conduct risk monitoring such as sales and marketing data
  • Is the firm using all data at its disposal to monitor customer outcomes?
  • How does this data fit with the overall compliance metrics?

Comparing outcomes across different customer groups: the FCA noted that product level metrics can hide significant variations in outcomes for specific customer groups and it expects firms to consider whether distinct groups are receiving worse outcomes compared to others.

  • Has the firm considered which metrics may indicate significant variability in outcomes for different customer groups?
  • Has the firm defined acceptable ranges of variability?
  • How has the firm compared outcomes between groups of customers?
  • What characteristics has the firm selected to compare groups (age, gender, ethnicity, socio-economic group, vulnerability)?
  • Where different outcomes have been identified between groups of customers, what action has the firm taken? Has the firm identified the root cause?

Actions taken to address risks/improve outcomes

Key and supplementary questions

Evidencing action/the ‘so what’ test: the FCA expects to see evidence of action taken following Duty implementation. In particular, what the firm has done to address crystallised issues and mitigate instances of potential risk, including where it had made changes to improve outcomes.

  • What has changed/improved post-Duty implementation?
  • What products, terms, pricing structures, distribution practices has the firm terminated or changed to be compliant?
  • What has the firm changed to ensure different groups of customers receive comparable outcomes?
  • Are there any practices the firm has changed to improve customer outcomes even though they were not identified as potential breaches?

Root cause analysis: firms need to identify and address the root causes of poor outcomes to effect meaningful, lasting change.

  • Has the firm identified the root cause of poor outcomes or risks to good outcomes?
  • What action has the firm taken to remediate the risk or the breach?

Business strategy impact

Key and supplementary questions

Facing to the future: learning from Duty findings, firms need to review their business strategy to ensure alignment with the Duty.

  • Is the firm’s business strategy aligned with delivering good customer outcomes?
  • What are the key conduct risks associated with the strategy/revenue growth plans? What are the key products and their risk features that the firm relies on in its strategy?
  • What monitoring will take place to ensure poor outcomes are not experienced by specific customer groups? Are the risks and breaches identified taken in consideration? What is the evidence of this reflection?


Key stakeholders preparing the report: recommended actions


Whilst the Board will ultimately sign off the report, the first line risk owners will be responsible for its development with inputs/oversight from second and third line.

Below we outline some actions and recommendations when planning and completing the report with a focus on the different roles of those involved in preparing the report.

  • Determine roles and responsibilities including the role of the second and third lines of defence (LoD): strong communication between LoDs and early determination of the best way to involve risk and internal audit are likely to make the reporting process smoother and provide the FCA with more robust evidence of compliance with the Duty. Some firms are considering dry-runs to ensure there is enough time to respond to Board challenge and reflect improvements in the Board report.
  • Identify the MI and data that will support the report and consider the need for outcomes testing: first line risk owners have been very busy putting in place the overall Duty framework. Firms need to assess if they have the right MI and should prioritise data build where necessary. Outcomes testing can assist firms in obtaining key evidence to support their assessment of compliance. It is essential that the report focuses on products and processes that have the most material impact on customer outcomes. This requires a firm to take a tailored approach to building the report, starting with identifying the data and MI that best evidence good outcomes and ultimately allow the firm to understand whether it is compliant with the Duty.
  • Build effective communications between data analysts, Duty Programme teams and accountable executives: the report will need to sum up and evidence the collective effort of several teams across the organisation. It is essential that communications between different teams are timely and effective to ensure the report is coherent and succeeds in telling the story of Duty compliance to the Board and the FCA.
  • Report plan: ensure all stakeholders, including the Board, are aligned on the detailed journey to report by July 2024 and develop the key actions to achieve this, from report skeleton, granularity, narrative building, key metrics to include, quality control over data used, any dry-runs and results of testing carried out by the second or third LoD or third parties.



By now, firms should be well on their way to gathering the data needed to prepare their first report. Time is of the essence, as data gaps and other issues will only become apparent as firms start the process of compiling their first report or dry-run. The FCA has made it clear that this is just the beginning of the Duty journey and firms will be expected to continue to improve in their Duty compliance efforts. To that end, having the right data and the right tools to interpret it will be essential. Through the Duty report, firms will have the means to explain how their efforts are contributing to better customer outcomes. Equally, the FCA will have the means to compare reports from different firms and identify good and bad practice as well as outliers. This means that investing early in getting the report right should pay off in terms of less supervisory challenge and a clearer roadmap to continue the Duty journey in the years ahead.

1 Consumer Duty Policy Statement: FCA Handbook PRIN 2A.8.3/4/5 R and PRIN 2A.9R

2 Compliance with the Duty meaning compliance with FCA Handbook Principle 12 and PRIN 2A

Meet the authors

Kareline Daguer


Kareline is a director in Deloitte’s EMEA Centre for Regulatory Strategy, specialising in insurance regulation. Kareline has more than 15 years of experience in both prudential and conduct insurance regulation, providing high quality advice to firms in the UK market. At Deloitte, Kareline leads a team of experts to carry out horizon scanning and assess the strategic impact of regulation on the market. Kareline provides advice to insurance clients on the impact of regulation on their business, finance, and operating models. Kareline has led engagements supporting clients with a number of regulatory challenges including Brexit and restructuring projects, advice on impact of Solvency II/ Solvency UK over capital decisions and investments, supporting a top 3 retail general insurer on interpretation and compliance with Pricing Practices rules, and design and implementation of insurance products and customer journeys for a large life insurer. Kareline is a member of the ICAEW Risk and Regulation Committee and the Solvency II working party. Kareline has authored several publications and columns on insurance regulation and Solvency II over the past ten years.  

David Clements


David has 25 years’ experience in the financial services industry and has significant experience across Retail Banking, Wealth Management and Insurance markets. David leads our National Retail Conduct and Governance team. David specialises in advising on compliance and conduct risk issues, ranging from SMCR, the design and development of conduct risk strategy and frameworks, leading our conduct assurance activity, including skilled person review and leading many of our large scale complex regulatory transformation projects.

David Strachan

Advisor, Regulatory Strategy

David is an Advisor for Deloitte on Regulatory Strategy. He focuses on the impact of regulatory changes - both individual and in aggregate - on the strategies and business/ operating models of financial services firms. David joined Deloitte after 12 years at the UK’s Financial Services Authority. His last role was as Director of Financial Stability, working with UK and international counterparts to deal with the immediate impact of the Great Financial Crisis and the regulatory reform programme that followed it.

Martin Shields


Martin leads Deloitte’s Major Programmes Financial Services team in Consulting. He has more than 20 years’ experience structuring and delivering large-scale, transformational change programmes in Banking and Capital Markets. His delivery experience spans complex Financial Services challenges, including technology, process and people / organisational changes to achieve valued business outcomes such as improved profitability, customer and employee experience, regulatory compliance, mergers and acquisitions and cultural change. He has specialised in driving strategic alignment of projects, programmes and portfolios, and ensuring that the benefits of change can be measurably and sustainably embedded into ‘Business as Usual’ operations. He is recognised as an expert in mobilising and architecting strategic change programmes, developing holistic and robust business cases, and communicating the potential that change can deliver to all audiences including executives and boards.

Paul Fraser


Paul is a Director in Deloitte’s Risk Advisory Practice. Paul specialises in Conduct Regulation, including developing and embedding conduct risk frameworks, managing regulatory change programmes and developing effective oversight structures for Asset and Wealth Managers. Paul holds a diploma from the Chartered Institute for Securities and Investments (CISI) and is Deloitte’s IMW sector lead for Consumer Duty.

Christopher Jamieson


Chris focuses on strategic regulatory and operational change across financial services, helping clients evolve through practical and risk-based advice to major regulatory topics, as well as through the use of RegTech solutions.

John Lonen


John is one of our retail conduct financial services leads. He has more than 20 years experience in complex remediation and regulatory driven transformation programmes. He leads our outcome testing hub. Most recently, John has supported a number of firms with implementation of the Consumer Duty, in particular product governance and price and value assessments. John is also helping firms consider how they drive operational efficiency and value through getting customer journeys ‘right first time’ and control and governance frameworks that are simplified and add value to the business.

Kat Andrews


Kat is a Director in Deloitte’s Risk Advisory Practice. She has over 23 years of financial services experience spanning Retail and Commercial Banking, General Insurance. Kat is our Banking and Retail Lending lead for Consumer Duty, leveraging her in-depth industry knowledge and understanding of regulatory expectations. Kat is also one of our Collections and Recoveries SME, but also has a focus on all aspects of consumer protection within retail lending, alongside an in-depth knowledge of assurance frameworks and outcome testing. Kat supports clients with regulatory change as well as compliance, including leading Skilled Person Reviews.

Junn Wei Tan


Junn is a Consultant in the EMEA Centre for Regulatory Strategy, focusing on retail conduct, consumer credit and sustainability regulations. Before joining Deloitte, Junn interned at UBS. Junn holds a Msc in Political Economy of Late Development with LSE.