In July 2026, the FCA published its review of firms’ approaches to outcomes monitoring under the Consumer Duty. Alongside examples of good practice, the regulator identified firms that were collecting management information (MI) without being able to demonstrate what that information revealed about customer outcomes, what action had been taken or whether outcomes had improved as a result.
The FCA’s review raises a practical issue for firms attempting to evidence good customer outcomes. While many organisations have invested heavily in MI and reporting frameworks, visibility of what customers are actually experiencing can still be limited. Where monitoring relies on small samples of customer interactions, signs of vulnerability, confusion or customer friction may never enter the reporting process.
Defining outcomes: What does good look like in practice?
The findings shared best practice examples where firms could demonstrate clearly how they’re defining what good customer outcomes looked like. Rather than relying on broad statements about fairness or customer satisfaction, they linked outcome expectations to specific stages of the customer journey and used monitoring to assess whether those outcomes were being delivered in practice.
That raises an important question for many firms: how do you know whether customers are consistently receiving good outcomes if only a small percentage of interactions are reviewed?
That’s why defining outcomes is an important first step – but firms also need sufficient visibility to assess whether those outcomes are being delivered consistently across products, channels and customer groups. The FCA highlighted positive examples of firms that translated customer outcome expectations into measurable indicators, enabling them to identify where outcomes were deteriorating and where intervention was required.
Defining outcomes, however, is only part of the picture. Firms also need a reliable way of identifying when those outcomes are not being achieved, often long before a complaint is raised or an issue appears in management reporting.
Customer interactions reveal what MI can miss
This is where customer journey monitoring becomes particularly valuable. The regulator places significant emphasis on understanding outcomes at different stages of the customer journey rather than relying solely on high-level indicators.
For example, a complaint, vulnerability disclosure or indication of customer confusion may not appear in management information until much later in the process. By that point, the outcome has already occurred. Therefore, by analysing customer conversations alongside existing MI, firms can gain greater visibility into how products and services are experienced in practice. This provides a richer understanding of customer outcomes than operational metrics alone.
The Consumer Duty’s core aim is to examine the customer experience. Those experiences are often most visible in the interactions that happen every day across contact centres, advice journeys, service teams and digital channels. The question then becomes whether firms are capturing enough of that information to understand what is really driving customer outcomes.
Are you measuring activity or outcomes?
The FCA’s findings also challenge firms to consider whether their existing MI is genuinely outcome-focused. Many businesses already track complaints, response times, case volumes and service levels. While these measures remain important, they do not necessarily explain whether customers are receiving good outcomes.
A board report may show that service standards are being met. It may not reveal whether customers understand key communications, whether vulnerable customers require additional support or whether avoidable barriers exist within the customer journey.
This is where interaction data can add another layer of insight. When firms analyse customer conversations alongside traditional MI, they can understand the drivers behind outcomes rather than simply measuring outputs. The FCA’s review suggests that firms which combine different sources of information are often better placed to identify emerging risks and evidence how outcomes are being monitored.
Vulnerability insights need more than a tick box
Vulnerability is one area where this becomes particularly evident. The FCA highlighted examples where firms struggled to show how outcomes differed across customer groups, including customers identified as vulnerable.
Most firms already capture information relating to vulnerability but the challenge is demonstrating how that information is being used to identify different outcomes, assess potential harm and improve support.
A broader view of customer interactions can help firms identify patterns that traditional quality assurance or complaint monitoring alone might miss. Firms increasingly need evidence that vulnerable customers receive appropriate support and achieve outcomes comparable to the wider customer population. That requires more than simply recording vulnerability characteristics. Firms also need to add ongoing monitoring of customer experiences and outcomes to the mix.
Better visibility leads to better decisions
Across the FCA’s examples of good practice, a consistent feature was the ability to link monitoring activity to meaningful action. Firms should not be simply collecting information – be able to demonstrate what they had identified, what they had done about it, and whether outcomes improved as a result.
The firms highlighted positively by the regulator were able to show how issues were identified, challenged and addressed – and how interventions led to improved outcomes. Achieving this requires timely and meaningful insight. The more complete the picture of customer outcomes, the easier it becomes to identify risks, evaluate trends and understand whether interventions are delivering the intended results.
Expanding MI alone is unlikely to solve the problem. Firms need confidence that they can identify emerging risks, understand customer experiences, and demonstrate how those insights influence decision-making.
Greater visibility of customer interactions can help close that gap, providing a stronger evidence base for outcomes monitoring and Consumer Duty oversight.
Frequently asked questions
What does the FCA expect from outcomes monitoring under the Consumer Duty?
The FCA expects firms to show how monitoring identifies customer risks, what actions have been taken, and whether those actions have improved customer outcomes.
Why are customer interactions important for outcomes monitoring?
Customer interactions can provide valuable insight into customer understanding, support needs, vulnerability indicators and potential harm that may not be visible through traditional management information alone.
Can MI alone demonstrate good customer outcomes?
Not necessarily. The FCA’s expectations are forfirms to understand what their MI is telling them, how it identifies risks and whether actions taken have improved outcomes.
Why is customer journey monitoring important?
Monitoring outcomes across different stages of the customer journey helps firms identify points of friction, confusion or potential harm before they become larger issues.
How can firms gain greater visibility of customer outcomes?
Many firms are combining traditional MI with interaction monitoring, quality assurance and customer journey analysis to build a more complete picture of customer outcomes across the business.
Recordsure helps firms transform customer interactions into actionable insight. By capturing, analysing and monitoring customer conversations at scale, Recordsure’s AI provides greater visibility of customer outcomes, vulnerability indicators, customer understanding and conduct risks. This enables firms to strengthen Consumer Duty oversight and build stronger evidence of good customer outcomes.
Get in touch today to discover how we can help your firm.
