About This Template
The FCA's Consumer Duty (PS22/9) came into force for open products and services on 31 July 2023. It sets a higher standard of consumer protection across financial services, requiring firms to act to deliver good outcomes for retail customers across four specific outcome areas. At its core, the Duty requires firms to focus not just on compliance with rules but on the actual outcomes customers experience — and to be able to demonstrate this to the FCA with evidence.
One of the most practically challenging elements of Consumer Duty for finance teams and compliance functions is the data and monitoring requirement. The FCA expects firms to define metrics for each outcome, collect evidence of whether those outcomes are being delivered, and present this evidence to the board in an annual Consumer Duty report. For firms that did not previously track outcomes-focused data, building this monitoring infrastructure from scratch is a significant undertaking.
This template provides the monitoring framework: an outcomes dashboard covering all four Consumer Duty outcomes, a complaint and outcome tracker for 12-month rolling data, and a structured template for the annual board report.
What's Included
Sheet 1 — Instructions
An overview of Consumer Duty: the four outcomes, the three cross-cutting rules, the principle of acting to deliver good outcomes for retail customers, and the board annual report obligation. Includes a summary of the FCA's expectations for outcomes monitoring data and what constitutes "good outcomes evidence".
Sheet 2 — Outcomes Dashboard
The central monitoring sheet, structured around the four Consumer Duty outcomes. For each outcome and sub-outcome, the dashboard records the metric, current result, target, RAG status, trend, evidence source, owner, and last updated date. Pre-populated with metrics across all four outcomes:
- Products and Services: Fair value assessment completion, product governance framework, target market definition, distribution strategy review.
- Price and Value: Price/value ratio assessment, fee transparency score, vulnerable customer pricing review, comparable pricing analysis.
- Consumer Understanding: Communications readability score (Flesch test), financial promotions approval rate, customer testing results, KID/KIID currency.
- Consumer Support: Average complaint resolution time, complaint upheld rate, vulnerable customer identification rate, service availability/uptime.
Sheet 3 — Complaint and Outcome Tracker
A 12-month rolling complaints and outcome tracker. Records monthly total complaints, upheld rate, root cause breakdown (product, pricing, communications, support), average time to resolve, and regulatory escalations. Designed to feed directly into the annual board report.
Sheet 4 — Board Annual Report Template
A structured template for the Consumer Duty annual board report. Sections include: Executive Summary, Outcomes Assessment for each of the four outcomes, Customer Harm Identification and Remediation, and Forward Plan. Blank narrative cells for each section allow you to add your firm-specific commentary alongside the quantitative data from the dashboard.
How to Use This Template
- Define your metrics and targets before collecting data. The most common mistake is collecting data first and then trying to decide what it means. For each metric in the Outcomes Dashboard, agree what "good" looks like before you start monitoring. This is what the Target column is for. The FCA will expect to see that your targets are stretching but realistic and that they are reviewed and updated as the firm matures.
- Assign an owner to each metric. Consumer Duty ownership should not sit entirely with compliance. Outcome ownership should be distributed: product teams own Products and Services metrics; pricing and finance own Price and Value; marketing and communications own Consumer Understanding; customer operations own Consumer Support. The board report is more credible when multiple senior owners can speak to their respective outcomes.
- Update the Outcomes Dashboard monthly or quarterly. The RAG status and trend columns allow you to identify deteriorating metrics before they become FCA concerns. Green does not mean no action required — you should still be reviewing and seeking improvement. Amber or Red should trigger a documented remediation plan.
- Use the Complaint Tracker to identify systemic issues. Individual complaints are resolved through the DISP process. But patterns in complaint root causes, upheld rates, or resolution times often reveal systemic issues with products, pricing, communications, or support processes. The tracker is designed to surface these patterns over a 12-month rolling period.
- Prepare the board report at least 6 weeks before the anniversary of Consumer Duty implementation. The board needs adequate time to review, challenge, and approve the report. Do not treat it as a last-minute compliance exercise — the FCA views the board report as evidence of genuine board oversight of consumer outcomes.
- Document customer harm and remediation actions explicitly. The board report must include not just positive outcomes data but also instances where the firm has identified customer harm, what caused it, and what has been done to remediate it and prevent recurrence. Firms that cannot identify any customer harm are likely not monitoring effectively enough.
Frequently Asked Questions
When is the Consumer Duty annual board report due?
The FCA requires firms to produce a Consumer Duty board report at least annually. For firms that implemented the Duty for open products and services on 31 July 2023, the first board report was due by 31 July 2024. Subsequent reports must be produced annually. There is no requirement to submit the report to the FCA — it is an internal governance document — but the FCA may request it as part of a supervisory review. The board must formally review, challenge, and approve the report. It is good practice to present the report at a scheduled board meeting rather than passing it on a written basis.
What counts as good outcomes evidence for Consumer Duty purposes?
Good outcomes evidence is data that demonstrates customers are actually experiencing the outcomes the Duty requires — not just that the firm has policies and processes designed to deliver those outcomes. Examples of outcomes evidence include: comprehension testing results showing customers understand product features and risks; customer journey data showing completion rates and drop-off points; complaint and upheld rate trends; pricing analysis showing value delivered relative to fees charged; vulnerable customer identification and support data; and post-sales outcome tracking (e.g. whether customers are using products as intended and achieving the objectives for which they were purchased).
Does Consumer Duty apply to B2B firms?
Consumer Duty applies to products and services provided to retail customers. The FCA defines retail customers broadly — it includes individuals, micro-enterprises (fewer than 10 employees and turnover under €2m), and small charities. B2B firms that serve only large corporates or institutional clients are generally outside the scope of Consumer Duty for those relationships. However, many firms operate in both B2B and B2C contexts, and firms that distribute retail products through B2B intermediary channels are still in scope for the outcomes their end retail customers experience. Manufacturers (product providers) have Consumer Duty obligations even if they distribute through intermediaries.
How should we identify and monitor vulnerable customers?
The FCA's guidance on vulnerability (FG21/1) defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm — particularly when a firm is not acting with appropriate levels of care. Drivers of vulnerability include health conditions, life events (bereavement, job loss), financial resilience (low or unstable income), and capability (low literacy or numeracy, lack of digital access). Firms should train staff to identify vulnerability signals; design products and processes that are accessible to vulnerable customers; and track metrics including the proportion of customers flagged as vulnerable, the outcomes those customers receive compared to non-vulnerable customers, and complaint rates among vulnerable customers.
What does the FCA expect for the Price and Value outcome specifically?
The Price and Value outcome requires firms to ensure that the price customers pay is reasonable given the benefits they receive. This does not mean the cheapest product wins — it means firms must be able to demonstrate that their pricing is fair relative to the value delivered. The FCA expects firms to conduct fair value assessments, document the factors considered (cost of production, profit margin, market comparables, consumer outcomes), and act on any assessment that identifies poor value. If a product is identified as providing poor value, the firm must either adjust the pricing, improve the product, or, in some cases, withdraw it from sale.
How frequently should we update and review the Outcomes Dashboard?
There is no prescribed frequency in the FCA's rules, but best practice is monthly monitoring for operational metrics (complaints, resolution times, service availability) and quarterly review for strategic metrics (fair value assessments, product governance framework, target market definitions). The annual board report draws on the full 12-month picture, so consistent monthly or quarterly data collection is important. The board report should not be the first time the board sees outcomes data — a Consumer Duty standing item on the management reporting pack, even if brief, demonstrates ongoing governance.
