Consumer Duty evidence: what good outcomes look like in advice

Most advice firms wrote a Consumer Duty policy, mapped their processes and briefed the team. The harder question comes later, usually from a board, a network supervisor or the regulator: how do you know your clients are getting good outcomes? A policy describes what the firm intends. Consumer Duty evidence shows what clients actually received, what the firm learned from it and what it changed as a result.

This guide sets out what the Duty asks firms to monitor, what the FCA has said good monitoring looks like, and a practical list of the evidence an advice firm can build from work it already does.

What the Duty asks you to evidence

The Consumer Duty was introduced by PS22/9 A new Consumer Duty. For open products and services, "the rules come into force on 31 July 2023", with closed products and services following on 31 July 2024. It is built around four outcomes:

• Products and services
• Price and value
• Consumer understanding
• Consumer support

Sitting above the outcomes are three cross-cutting obligations in PRIN 2A.2:

• PRIN 2A.2.1R: "A firm must act in good faith towards retail customers."
• PRIN 2A.2.8R: "A firm must avoid causing foreseeable harm to retail customers."
• PRIN 2A.2.14R: "A firm must enable and support retail customers to pursue their financial objectives."

None of these can be shown with a policy document alone. Each one is a question about what happened to real clients, which is why monitoring sits at the centre of the Duty.

The monitoring rule in PRIN 2A.9

The monitoring requirement is set out in PRIN 2A.9. PRIN 2A.9.8R says firms must "regularly monitor the outcomes retail customers receive from: (1) the products the firm manufactures or distributes; (2) the communications the firm has with retail customers; and (3) the customer support the firm provides".

For an advice firm, those three strands map neatly onto everyday work:

• Products and services: the recommendations you make, the products you place business into and the ongoing service clients pay for.
• Communications: suitability reports, annual reviews, scopes of work, fee disclosures and what is said in meetings.
• Customer support: how quickly you respond, how you handle complaints and how you adapt your service for clients who need it.

The key word is "regularly". A one-off review at implementation does not meet the expectation. Monitoring is an ongoing activity that should keep producing information the firm can act on.

What the FCA says good outcomes monitoring looks like

In July 2026 the FCA published Outcomes monitoring: good practice and areas for improvement. It says firms should be able to show "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."

That is a four-step loop: information, interpretation, action and re-testing. The same publication lists the areas where firms fell short:

• no audit trail from management information (MI) to decisions;
• unclear thresholds for what counts as harm;
• fixes that were not tested to see whether they worked;
• limited challenge from the board.

There is helpful news for smaller firms. The FCA says smaller firms "could use a focused set of indicators without complex systems or large teams". What matters is that they can explain what their information shows, how it helps them identify harm or poor outcomes, and what they do in response. A spreadsheet of a dozen well-chosen measures, reviewed and acted on, is a reasonable starting point. A long dashboard nobody acts on is not.

Consumer Duty evidence for an advice firm: a working list

The table below is a practical starting point, organised by outcome. It is not an exhaustive or official list. Your own evidence should reflect your client base, your services and the risks you have identified.

It is also worth reading the FCA's Consumer Duty focus areas. For advice and wealth firms, the priorities listed include "Tackling poor identification of clients with characteristics of vulnerability by wealth managers", "Expectations for wealth and advice firms when assessing fair value" and "Risks to providing unsuitable advice". If your evidence is thin in any of those three areas, that is where to start. We cover vulnerability in more detail in identifying vulnerable clients in meetings.

Turning file reviews into outcome evidence

For an advice firm, the client file is where most outcomes become visible. It holds the fact find, the risk assessment, the recommendation, the disclosures and the record of each review. If the file is sound, there is a good chance the outcome was too. If it is not, the file usually shows you where things went wrong.

The problem is coverage. A thorough file review takes a compliance reviewer around half a day, so most firms check a sample. A sample can tell you something, but it leaves most of the back book unseen, and it makes trends hard to spot. We explain the trade-off in why most firms only check a sample of files.

This is the job Scrutineer was built for. It reads a whole client folder, including every subfolder and scanned documents, and returns:

• a compliance score against FCA suitability and disclosure standards, and a file-quality score against your firm's own standard;
• an overall verdict of Suitable, Unclear or Unsuitable;
• findings tied to named rules, such as COBS 6.1A or PRIN 2A.4, with the supporting passage quoted from the file;
• outstanding file actions and a missing-document checklist;
• a comparison of review periods, so you can see whether a file improved or slipped year on year.

By our estimate, a review that takes half a day by hand takes minutes with Scrutineer. That makes it realistic to review every file, which turns file checking from an occasional sample into a steady source of MI. Scrutineer produces the evidence and the findings. The judgements about what the findings mean, and what to do about them, stay with your compliance team and your governing body.

Closing the loop

Evidence only counts if it leads somewhere. Using the FCA's four steps, a simple loop for an advice firm looks like this:

1. Set thresholds. Decide in advance what level of a measure would concern you, for example a rise in Unclear file verdicts or ongoing reviews not delivered.
2. Record the decision. When a threshold is crossed, write down what you concluded and who decided. This is the audit trail from MI to decisions the FCA found missing.
3. Act and assign. Remediation for individual clients, training for an adviser, a change to a template or process.
4. Re-test. Check the same measure again later and record whether the action improved outcomes.
5. Report upwards. Feed the results into the annual report to your governing body. Our guide to the Consumer Duty board report covers what that should contain.

Frequently asked questions

Does a small advice firm need a complex MI system to evidence the Consumer Duty?

No. The FCA's outcomes monitoring publication says smaller firms could use a focused set of indicators without complex systems or large teams. What matters is that they can explain what their information shows, how it helps them identify harm or poor outcomes, and what they do in response.

Is a Consumer Duty policy enough evidence on its own?

A policy shows intent. PRIN 2A.9.8R requires firms to regularly monitor the outcomes clients actually receive from products, communications and customer support, so you need records of what happened to clients and how you responded.

Can software make a firm Consumer Duty compliant?

No. Tools like Scrutineer can read files, apply the rules consistently and produce evidence quickly, which makes wider monitoring practical. Responsibility for the outcomes, the judgements and the actions stays with the firm.

If you would like to see how whole-file reviews can feed your outcomes monitoring, read more about Scrutineer or book a twenty-minute demo with Adam Booth on Microsoft Teams. It runs live on a demo firm, so there is nothing to prepare.