The Consumer Duty board report: a practical guide for advice firms

Once a year, every firm subject to the Consumer Duty has to put a report on client outcomes in front of its governing body. In a large firm that is a formal board exercise. In a small advice firm it may be two or three directors around a table. Either way, the Consumer Duty board report is the moment the firm has to say, in writing, whether it is delivering good outcomes and what it is going to do next.

The FCA has now looked at two years of these reports. This guide covers what the rules require, what the regulator found, and how an advice firm can build a report whose figures lead clearly to conclusions and actions.

What PRIN 2A.8 requires

The requirement sits in PRIN 2A.8. It begins "At least annually, the governing body of a firm must…" and goes on to require the governing body to review and approve the firm's report on the outcomes retail customers are receiving, confirm whether it is satisfied that the firm is complying with the Duty, and assess whether the firm's future business strategy is consistent with it. When approving the report, the governing body must also agree any actions needed to address risks or poor outcomes it identifies.

Three things follow from that wording:

• It is the governing body's report. Compliance may draft it, but the governing body reviews it, reaches a view and owns the actions.
• Annual is the minimum. Nothing stops a firm reviewing outcomes more often, and a quarterly look at the same measures can make the annual report far easier to write.
• It must end in decisions. A report that describes activity without agreeing actions does not do what the rule asks.

One change worth knowing: in an update of 27 February 2025 to PS22/9, the FCA said "We no longer expect firms to have a Consumer Duty Board champion." Firms can keep one if it helps, but it is no longer an expectation.

What the FCA found in year two

In April 2026 the FCA published a blog, Year 2 Consumer Duty Board Reports: progress and what comes next. It recorded progress: "Boards now formally review and approve reports". It also found that "the quality and depth of analysis was variable", and it highlighted three weak points:

• data that was not linked to outcomes;
• weak monitoring of third-party distribution;
• board challenge that was poorly recorded.

Those findings echo the FCA's July 2026 publication on outcomes monitoring, which found no audit trail from MI to decisions, unclear harm thresholds, fixes that were not tested, and limited board challenge. The common thread is that firms gather plenty of numbers but struggle to show what those numbers mean and what they did because of them.

What goes in a Consumer Duty board report for an advice firm

There is no single right structure. The outline below is one we find works for advice firms because it follows the order in which a governing body needs to think.

1. Summary and conclusion. One page: is the firm delivering good outcomes, where are the concerns, and what actions are proposed.
2. Scope and data sources. What the report covers, which client groups, which period, and where each measure comes from.
3. The four outcomes. A section each on products and services, price and value, consumer understanding and consumer support, set out in PS22/9.
4. Cross-cutting obligations. Evidence that the firm acts in good faith, avoids foreseeable harm and supports clients to pursue their financial objectives, as PRIN 2A.2 requires.
5. Different groups of clients. Whether outcomes differ for some clients, including those with characteristics of vulnerability.
6. Last year's actions. What was agreed, what was done, and whether it improved outcomes.
7. This year's actions. Owners, deadlines and how success will be measured.
8. Governing body discussion. The challenge raised, the answers given and the conclusion reached.

Sections 6 and 8 answer two of the FCA's findings directly: fixes that were not tested, and challenge that was poorly recorded.

Making MI link to outcomes

The fix for "data not linked to outcomes" is to start each measure with a question about clients rather than a count of activity. For every figure in the report, ask: what does this tell us about the outcome a client received, and what level would worry us?

The thresholds are examples, not FCA requirements. The point is that they are set in advance and written down, so the governing body can see when a measure has moved into territory that demands a response.

The FCA's outcomes monitoring publication also offers a useful test for each section. Firms should be able to explain "What their information tells them", "How they use it to identify risks or issues", "What action they take in response" and "How they consider whether those actions have improved outcomes." If a section of your report cannot answer all four, it is not finished. Our companion piece on Consumer Duty evidence sets out what evidence to gather under each outcome.

Recording board challenge properly

Challenge that happened in the room but is not in the minutes is, for evidence purposes, challenge that did not happen. A few habits help:

• circulate the report early enough for members to read it and prepare questions;
• minute each substantive question, who asked it and the answer given;
• record where the governing body disagreed with the draft, and what changed as a result;
• record the final confirmation and the agreed actions in the governing body's own words.

For smaller firms, the FCA has said they could use a focused set of indicators without complex systems or large teams, provided they can explain what their information shows and what they do in response. The same proportionality applies here: short minutes are fine, as long as they show real scrutiny.

Where file review data fits

For most advice firms, the strongest single source of outcome evidence is the client file. The difficulty is volume. A thorough review takes around half a day by hand, so many firms report on a small sample, which makes trends hard to show with confidence.

Scrutineer reads a whole client folder, scores it for FCA compliance and for your firm's own file-quality standard, gives a Suitable, Unclear or Unsuitable verdict, and ties each finding to a named rule with the passage quoted from the file. Its dashboard shows every check with both scores and the verdict, and it compares review periods so you can see whether files have improved. By our estimate that cuts a review from half a day to minutes, which makes reporting on every file a realistic option.

Scrutineer gives the governing body better information. It does not write the board's conclusions or confirm compliance on the firm's behalf. That judgement, and the responsibility for it, stays with the governing body.

Frequently asked questions

How often must a Consumer Duty board report be produced?

At least annually. PRIN 2A.8 requires the governing body, at least once a year, to review and approve a report on retail customer outcomes, confirm whether it is satisfied that the firm is complying with the Duty, and agree any actions needed.

Do we still need a Consumer Duty board champion?

The FCA said on 27 February 2025: "We no longer expect firms to have a Consumer Duty Board champion." Firms may still choose to have one.

What was the most common weakness in year two board reports?

The FCA's year two blog found analysis quality was variable, with data not linked to outcomes, weak third-party distribution monitoring and poorly recorded board challenge among the weak points.

To see how whole-file review results can feed your next board report, read about Scrutineer or book a twenty-minute demo on Microsoft Teams with Adam Booth, run live on a demo firm with nothing for you to prepare.