As firms prepare their third annual Consumer Duty board reports, there is a risk that the process starts to feel routine. Governance frameworks are established, reporting cycles are embedded, and boards have been through this exercise before.
Yet this is where the real challenge begins.
The early years of Consumer Duty were largely focused on implementation. Firms built governance structures, reviewed products and services, assessed customer journeys and invested in new management information (MI). Many now have more mature reporting packs, clearer accountability and stronger board oversight.
The question is no longer whether a Consumer Duty framework exists, but whether firms can demonstrate that customers are receiving good outcomes in practice.
Key takeaways
- Consumer Duty board reports should focus on customer outcomes, not just governance processes.
- Boards need evidence that helps them understand what customers are actually experiencing.
- Consumer understanding and consumer support remain among the hardest outcomes to assess.
- Customer interactions can provide valuable insight into emerging risks and areas of potential customer harm.
- Stronger evidence supports more effective board challenge and decision-making.
From governance evidence to customer evidence
The FCA’s recent reflections on Consumer Duty board reporting suggest the focus is increasingly shifting beyond whether governance arrangements are in place and towards how firms assess customer outcomes and respond when risks emerge.
Boards are expected to understand what monitoring is revealing, where issues may be developing and how insights are driving action.
For many firms, that means moving from governance evidence to customer evidence.
Traditional MI remains important. Complaint volumes, cancellation rates, quality assurance scores, customer satisfaction measures and vulnerability metrics can all provide valuable indicators of performance.
However, these measures do not always explain what customers have actually experienced.
A low level of complaints does not necessarily mean customers understood a product. A completed process does not automatically demonstrate that communications were effective. A customer interaction may have followed the correct procedure without necessarily delivering the support a customer needed.
Consumer Duty requires firms to understand not only what happened, but whether good customer outcomes were achieved as a result.
Avoiding routine Consumer Duty reporting
The annual board report should not become an exercise in repeating last year’s process.
The FCA’s review of second-year board reports highlighted areas where firms can continue to strengthen their approach, including linking data more clearly to customer outcomes, demonstrating meaningful board challenge, improving oversight of third parties, and strengthening their assessment of consumer understanding and support.
These observations reflect a broader regulatory theme. Having governance structures in place is important, but firms must also be able to demonstrate that those structures are delivering tangible value for customers.
Boards should therefore be asking more challenging questions:
- What is our MI really telling us?
- Where are customers encountering difficulty?
- How do we know customers understand key information?
- What customer evidence supports our conclusions?
- Are there emerging risks that are not yet visible through complaints or traditional metrics?
The most valuable discussions are often not about the metrics firms already have, but about the questions those metrics raise.
Why customer interactions matter
One of the most difficult aspects of the Consumer Duty is assessing outcomes such as consumer understanding and consumer support.
These outcomes cannot always be measured through a dashboard or a single performance metric. They depend on how customers receive, interpret and act on information throughout their journey.
This is why customer interactions are becoming an increasingly important source of evidence.
Every day, firms generate significant amounts of data through telephone calls, video meetings, emails, webchat conversations and other customer communications. Within those interactions sits valuable information about whether customers appear to understand key information, whether support is meeting their needs and whether indicators of vulnerability are being recognised appropriately.
Customer interactions can also highlight early signs of potential problems before they emerge through complaint trends, remediation activity or other traditional indicators.
For boards seeking a more complete view of customer outcomes, this evidence can provide valuable context alongside existing management information.
How interaction intelligence can support board oversight
Technology is increasingly helping firms analyse larger volumes of customer interactions and identify patterns that might otherwise be missed through traditional monitoring approaches alone.
Used appropriately, interaction analytics can help firms:
- identify potential indicators of customer misunderstanding
- highlight recurring themes and emerging risks
- strengthen oversight of customer support activities
- provide additional evidence when assessing customer outcomes
- support more informed board discussions and decision-making
Interaction analytics should be considered alongside other sources of evidence rather than in isolation.
Boards should continue to draw on a range of quantitative and qualitative evidence, including management information, complaints data, quality assurance reviews and customer feedback.
The objective is not to automate judgement. It is to provide a richer understanding of the customer experience.
At Recordsure, we are seeing increasing interest in interaction analytics as firms look to strengthen their Consumer Duty evidence frameworks and gain deeper insight into customer outcomes.
Better evidence leads to better challenge
One of the FCA’s consistent messages is the importance of meaningful challenge from governing bodies.
Boards need to demonstrate how they have tested information, challenged assumptions and required action where appropriate.
That challenge is only as effective as the evidence available.
When boards have access to richer customer outcome insights, they are often better placed to ask the questions that matter most:
- What is driving this trend?
- How confident are we in our conclusions?
- What customer evidence supports this position?
- Are we identifying risks early enough?
- Are our interventions improving outcomes?
These conversations help move firms beyond reporting activity and towards genuine outcome oversight.
Consumer Duty is now an ongoing discipline
The next phase of Consumer Duty is less about building frameworks and more about demonstrating that those frameworks continue to deliver good customer outcomes.
Recent FCA observations suggest increasing focus on how board reports support decision-making, oversight and the delivery of customer outcomes.
That requires firms to build a more complete picture of the customer experience, challenge assumptions, identify emerging risks and act when outcomes fall short.
For many firms, customer interactions can provide valuable evidence of customer experiences and outcomes. The challenge is turning that evidence into meaningful insight.
By combining governance, oversight and customer interaction intelligence, firms can strengthen their understanding of customer outcomes, support better decision-making and build greater confidence that their Consumer Duty framework is delivering what it is designed to achieve: consistently good outcomes for customers.
Want to strengthen the evidence behind your next Consumer Duty board report? Speak to Recordsure about how interaction intelligence can help turn customer conversations into clearer insight for oversight, challenge and decision-making.
Frequently asked questions
What should a Consumer Duty board report include?
A Consumer Duty board report should provide an assessment of customer outcomes, identify any areas where outcomes may not be meeting expectations, summarise actions taken during the reporting period, and explain how the board has provided oversight and challenge.
What is the FCA focusing on in Consumer Duty board reports?
The FCA’s recent commentary suggests firms should be able to demonstrate how they assess customer outcomes, identify emerging risks, challenge assumptions, and take action where improvements are needed. The focus is increasingly on evidence of outcomes rather than the existence of governance processes alone.
How can firms evidence consumer understanding?
Consumer understanding can be evidenced through a combination of customer feedback, testing of communications, behavioural insights, customer interaction reviews, complaints analysis and outcome monitoring. No single metric is likely to provide a complete picture.
Why are customer interactions important for Consumer Duty?
Customer interactions can provide direct evidence of how customers experience products, services, communications and support. They can also help firms identify potential misunderstandings, vulnerability indicators and emerging risks that may not yet be visible through traditional MI.
Can technology help with Consumer Duty oversight?
Technology can help firms analyse larger volumes of customer interactions and identify trends, themes and risks. However, it should complement, not replace, governance, professional judgement and board accountability.
How can boards improve the quality of Consumer Duty reporting?
Boards can improve reporting by focusing on customer outcomes rather than reporting activity, challenging assumptions, seeking evidence from multiple sources, and ensuring that management information is translated into meaningful decisions and actions.
