Where You Should Be Today
Nine days before the deadline, the year-two board report should be:
- Substantively complete in draft form, with all four consumer outcomes sections written and evidenced.
- Distributed to the board — or at minimum the chair and audit committee chair — for pre-read.
- Reviewed by external counsel or compliance adviser where that has been the pattern in prior years.
- Aligned with the price-and-value assessment (CFO-owned) and the governance and MI statement (also CFO-owned).
If any of those four is not yet true, the final week involves triage — deciding what to complete, what to shorten, and what to defer to next year with an explicit note in the report.
The Ten Verification Items
Ten specific items to check in the final week before board sign-off.
- Every outcome section has data, not assertions. "We monitor consumer understanding" is an assertion. "Comprehension testing on Product X in Q2 showed 78 per cent of retail customers correctly identified the fee structure, up from 71 per cent in Q4 last year" is data. Every outcome needs the second version, not the first.
- Vulnerability identification rates are disclosed. Specific percentage or count of customers identified as vulnerable, movement year-on-year, and the specific channels through which identification is happening.
- Price and value is refreshed for 2026. Not carried forward from year-one benchmarking. Current unit economics, current benchmark comparison.
- MI is evidenced with specific management actions. Three concrete examples in the past twelve months where MI drove a management response.
- Complaints trend analysis is broken by outcome category. Not aggregate complaints; complaints tagged to which of the four outcomes they relate to.
- Residual Duty risk is stated honestly. A "we are fully compliant across all four outcomes" claim is not credible. Where risks remain, name them.
- AI use in customer processes is addressed. Any use of AI in customer-facing decisions, communications or support is disclosed with the associated Consumer Duty governance.
- Vulnerable customer support pathway outcomes are measured. Not just identification — the outcomes for the customers once identified.
- The governance statement names specific senior managers. SMFs by name accepting accountability, not "the executive committee".
- Year-on-year movement is tabulated. Every outcome metric shown as this year vs last year with the direction of movement.
The Three Language Traps
Three specific patterns of language reliably need fixing in the final week.
Overclaim
"We deliver good outcomes across all four consumer outcomes for all our customers, all the time." No firm can defend this in a supervisory review. Replace with specific evidence of what has been achieved, and honest acknowledgement of where residual risk remains.
Process Description Masquerading as Outcome
"We have implemented processes to monitor consumer support outcomes." This is a description of what the firm has done, not what has changed for customers. Replace with "customer support satisfaction score is 4.3/5 in H1 2026, up from 4.1 in H2 2025, with the improvement driven by [specific factor]".
Governance Statement Passivity
"The board has satisfied itself that appropriate governance is in place." Passive, unsubstantiated. Replace with "the board has reviewed the Duty MI at each of its four meetings during the reporting period, and has taken the following specific decisions in response: [three named decisions]".
The CFO-Owned Sections Most Often Needing Last-Minute Rewrite
Three sections that are almost universally CFO-owned in substance regardless of the org chart, and that reliably need late-cycle attention.
Price and Value
The refreshed unit-economic and benchmark analysis. If the data quality has slipped (some products under-analysed, some benchmarks outdated), the final-week fix is to name explicitly which products have been fully assessed and which have been assessed on a lighter basis with a stated plan for full assessment in the next twelve months. Do not over-claim coverage.
Governance and MI Statement
The board's attestation that MI is adequate to monitor Duty outcomes. Verify: the specific MI metrics, the source system for each, the reporting cadence to the board, and — most importantly — the specific actions the board has taken in response to MI signals. If you cannot cite three concrete actions from the past twelve months, the statement is not evidenced and the board should not sign it in its current form.
Cost of the Duty Programme
An honest statement of the ongoing operating cost of the Duty. Understated cost lines can flag credibility questions in supervisory review; over-stated ones invite questions about programme efficiency. Landing this in a defensible range is a CFO discipline.
"The board that signs a Consumer Duty year-two attestation is signing a document that will be a primary evidence source in any subsequent supervisory review or enforcement action. The final week is when the language gets fixed to match what the firm can actually defend. Boards that sign attestations they cannot defend put themselves and the firm at risk."
The Final-Week Calendar
Key Takeaways
- Nine days from now the Consumer Duty year-two board attestation is due (31 July 2026). Final-week polish, not substantive drafting.
- Ten verification items dominated by one central discipline: replace assertions with data across every outcome section.
- Three language traps to sweep: overclaim, process description masquerading as outcome, governance statement passivity.
- Three CFO-owned sections that reliably need late-cycle attention: price and value, governance and MI statement, cost of the Duty programme.
- Final-week calendar: verification Wed 22 Jul, language sweep Thu 23 Jul, CFO sections Fri 24 Jul, chair review Mon 27 Jul, board sign-off Wed 29 Jul, buffer Thu/Fri.
- The document being signed will be primary evidence in any subsequent supervisory review or enforcement action. Sign only what the firm can defend.