Consumer Duty Board Pack: What Your Board Needs to See

What It Is

A Consumer Duty board pack is the structured management information that enables your board or governing body to assess whether the firm is delivering good outcomes for retail customers across the four outcome areas defined in PRIN 2A. It is the primary governance mechanism through which senior leadership discharges its Consumer Duty obligations — and the primary document the FCA will ask to see when assessing whether your board is genuinely engaged with Consumer Duty.

The board pack is not a compliance report. It is an operational governance document that should present data, analysis, and recommended actions across products and services, price and value, consumer understanding, and consumer support. It must be specific to your firm's business model, grounded in real MI rather than generic commentary, and structured to enable the board to make decisions — not simply receive information.

The FCA's July 2023 Dear CEO letters and subsequent multi-firm review findings have made one thing unambiguous: boards that receive superficial, high-level summaries without granular data on customer outcomes are not meeting the standard. The regulator expects boards to interrogate their Consumer Duty MI with the same rigour they apply to financial performance data. A board that rubber-stamps a quarterly Consumer Duty slide deck is a board that is failing in its governance role.

Why the FCA Cares

The FCA introduced the annual outcomes assessment requirement under PRIN 2A.9 precisely because it wanted board-level accountability for Consumer Duty. The regulator's experience under Treating Customers Fairly was that customer outcomes reporting rarely reached the board in a form that enabled meaningful challenge. Compliance functions produced reports; boards noted them; nothing changed.

Consumer Duty is different by design. The FCA expects the board to own the firm's Consumer Duty performance, not delegate it entirely to compliance. This means the board must receive MI that is sufficiently granular to identify where outcomes are good, where they are deteriorating, and where specific customer groups — particularly vulnerable customers — are experiencing differential harm. The FCA's 2024 and 2025 multi-firm reviews have consistently criticised firms whose board reporting aggregates data to a level that masks pockets of poor outcomes.

The FCA has also connected Consumer Duty board reporting directly to SM&CR. The Senior Manager with prescribed responsibility for Consumer Duty (typically SMF24 or SMF1) must be able to demonstrate what MI they reviewed, what questions they asked, and what actions resulted. Board minutes that show passive receipt of information without challenge or follow-up are evidence of inadequate senior management oversight.

The regulator has signalled that its supervisory approach to Consumer Duty will increasingly focus on governance effectiveness. Firms that can demonstrate a robust board pack — with real data, genuine analysis, and tracked remediation — are materially less likely to face intensive supervisory intervention than firms whose board reporting is performative.

Who It Affects

Every FCA-authorised firm that falls within the scope of Consumer Duty needs a mechanism for board-level outcomes monitoring. The form and complexity of the board pack will vary with the firm's size, business model, and customer base, but the obligation is universal.

For larger firms with diverse product ranges and multiple distribution channels, the board pack will necessarily be substantial. It should cover each product line, each distribution channel, and each customer segment with sufficient granularity to identify differential outcomes. These firms often need a dedicated Consumer Duty committee or sub-committee that conducts detailed analysis before presenting synthesised findings to the main board.

For smaller firms — sole traders, small IFA practices, boutique brokers — the board pack may be a simpler document, but it must still contain real data. A small mortgage advice firm, for example, should be tracking suitability outcomes, complaint volumes and root causes, customer feedback on communications clarity, and any barriers to switching or cancelling. The FCA has explicitly rejected the argument that proportionality means small firms can avoid substantive reporting. Proportionality applies to complexity, not to rigour.

Firms operating through appointed representative networks face an additional layer of complexity. The principal firm's board pack must include MI on outcomes delivered through the AR network, and the principal must be able to demonstrate that it is monitoring AR performance against Consumer Duty standards. This is an area of heightened FCA focus following the 2024 AR multi-firm review.

What Firms Get Wrong

The most common failure is producing a board pack that reports activity rather than outcomes. Firms describe what they have done — "we conducted a fair value assessment," "we updated our communications," "we trained staff on Consumer Duty" — without presenting data on whether customers are actually experiencing good outcomes. The FCA does not care what you did; it cares what effect it had.

The second systemic failure is aggregation that conceals harm. A firm reporting a 92% customer satisfaction score looks healthy — until you disaggregate and discover that satisfaction among customers over 65 is 61%, or that customers who tried to cancel experienced a 40% complaint rate. The FCA has been explicit, including in its October 2024 portfolio letter to consumer credit firms and its March 2025 wealth management findings, that aggregate MI is insufficient. Board packs must segment outcomes by customer group, product, channel, and where relevant, vulnerability characteristics.

Third, firms treat the board pack as a backward-looking report rather than a forward-looking governance tool. An effective board pack does not simply describe what happened last quarter. It identifies emerging trends, flags leading indicators of potential harm, and presents options for board decision. If complaint volumes in a specific product line are rising, the board pack should analyse why, quantify the potential customer impact, and propose remedial actions with timelines and owners.

Fourth, action tracking is weak or absent. Many firms present findings to the board but do not systematically track whether remedial actions are completed, whether they are effective, and whether outcomes improve as a result. The FCA expects a closed-loop process: identify, act, measure, report back. Board packs that raise the same issues quarter after quarter without resolution are evidence of governance failure.

Finally, firms frequently fail to connect their complaints MI to their Consumer Duty reporting. Complaints data is one of the richest sources of outcomes intelligence available to any firm, yet many board packs treat complaints reporting and Consumer Duty reporting as separate streams. Under Consumer Duty, these must be integrated — complaint trends, root causes, and FOS uphold rates should feed directly into the outcomes analysis for each of the four outcome areas.

What Evidence Is Expected

The FCA expects the board pack to contain quantitative MI mapped to each of the four outcomes, supplemented by qualitative analysis that interprets the data and identifies action points. Generic narrative without supporting data is insufficient; raw data without analysis is equally inadequate.

For products and services (Outcome 1), the board should see data on whether products are reaching their intended target market, product review outcomes, distribution monitoring results, and any instances where products have been sold outside the target market. Where the firm manufactures products, evidence of ongoing product governance — including assessments of whether existing products continue to meet customer needs — should be presented.

For price and value (Outcome 2), the board needs fair value assessment outcomes for each product line, including any changes to pricing, commissions, or fee structures that resulted from the assessment. Where the firm has identified groups of customers receiving poor value, the board pack should present the remediation plan and track its progress.

For consumer understanding (Outcome 3), evidence should include communication testing results, customer comprehension metrics (such as survey data or behavioural proxies like early cancellation rates), and any changes made to communications as a result of testing. Readability scores alone are not sufficient — the FCA wants evidence that customers actually understand what they are buying.

For consumer support (Outcome 4), the board should see channel availability data, average response and resolution times, complaint volumes and trends, FOS referral and uphold rates, and analysis of any friction points in the customer journey — particularly around switching, cancelling, or making claims. Differential support outcomes for vulnerable customers must be separately reported.

The annual outcomes assessment, required under PRIN 2A.9.17R, must synthesise the year's MI into a formal board-approved document. This assessment should explicitly evaluate performance against each outcome, identify areas for improvement, and set out the firm's plan for the coming year. The FCA has indicated it will request annual assessments during supervisory engagements and will use them as a primary indicator of governance quality.

Good Implementation Looks Like

A firm with effective Consumer Duty board reporting has designed its MI framework around its specific business model and customer base, not around a generic template. The board pack is structured around the four outcomes but tailored to the firm's products, distribution channels, and risk profile. A consumer credit firm's board pack will look materially different from a wealth manager's — and it should.

The MI is genuinely decision-useful. Each section presents data, identifies trends, compares performance against internal targets and external benchmarks where available, and concludes with a clear assessment: green, amber, or red, with supporting rationale. Amber and red ratings trigger documented action plans with named owners, deadlines, and measurable success criteria.

The board engages actively with the pack. Minutes reflect substantive discussion, challenge, and decision-making — not passive receipt. Board members ask questions about the data, challenge the analysis, and hold senior managers accountable for progress on remediation actions. The Consumer Duty senior manager presents the pack personally and is prepared to answer detailed questions.

Vulnerable customer outcomes are reported separately and prominently. The firm can demonstrate that it has identified its vulnerable customer population (using the FCA's vulnerability drivers: health, life events, resilience, and capability), tracked outcomes for this group, and taken specific action where outcomes are worse than for the general customer population.

The pack includes a rolling action tracker that shows all open Consumer Duty remediation actions, their current status, and their expected completion dates. Completed actions are assessed for effectiveness — did the intervention actually improve outcomes? — before being closed. The board can see at a glance the total remediation workload, any overdue items, and the overall trajectory of the firm's Consumer Duty performance.

Root cause analysis from complaints data is integrated into the outcomes reporting. Where complaints reveal systemic issues — a product feature that consistently generates confusion, a communication that misleads, a process that creates unnecessary friction — these feed directly into the relevant outcome section with a linked remediation action.

Related Tool

The MEMA Consumer Duty tool provides a structured framework for building and maintaining your board pack. It maps your management information against each of the four outcomes, tracks data quality and completeness, and generates board-ready reports that present quantitative MI alongside qualitative analysis.

The tool includes an action tracker that links identified issues to remediation plans, assigns ownership, sets deadlines, and monitors progress. It flags overdue actions and generates exception reports for board attention. When the annual outcomes assessment is due, the tool synthesises the year's quarterly data into a comprehensive assessment document, ensuring consistency between your ongoing reporting and the formal annual evaluation.

Vulnerable customer outcomes monitoring is integrated throughout. The tool segments outcome data by vulnerability characteristics, flags differential outcomes for investigation, and ensures that your board pack presents a clear picture of how your firm is serving its most at-risk customers — exactly the analysis the FCA expects to see.

Related Service

Our Consumer Duty implementation service includes board pack design as a core deliverable. We work with your compliance team and senior management to design an MI framework that is tailored to your business, proportionate to your scale, and aligned with FCA expectations as expressed in published multi-firm review findings, portfolio letters, and supervisory communications.

For firms that have already built a board pack but are unsure whether it meets the standard, we offer an independent review. We assess your MI against what the FCA is actually looking for — not a theoretical checklist, but the practical questions supervisors ask during firm visits and desk-based reviews. We identify gaps, recommend enhancements, and help you prioritise improvements based on regulatory risk.

We also support annual outcomes assessment preparation. This includes reviewing your data completeness, stress-testing your analysis, drafting or reviewing the assessment document, and preparing the presenting senior manager for board discussion. Our consultants have direct experience of how the FCA engages with these documents during supervisory interactions, and we bring that perspective to every engagement.

Related Sectors

Consumer credit firms face particular intensity of Consumer Duty scrutiny, driven by the FCA's ongoing focus on high-cost credit, motor finance commissions, and buy-now-pay-later products. Board packs in this sector must address price and value with rigour — the FCA's fair value expectations for consumer credit are among the most demanding across any sector. Complaints MI is critical, as consumer credit consistently generates the highest FOS referral volumes.

Wealth management firms must demonstrate that ongoing advice charges represent fair value, particularly as portfolios grow and percentage-based fees generate increasing revenue without proportionate increases in service. Board packs should track the relationship between charges and service delivery, suitability outcomes, and whether investment performance is consistent with the client's risk profile and objectives.

Insurance brokers navigate a complex dual role as both manufacturers (where they design bespoke arrangements) and distributors. The board pack must address both functions, with particular attention to commission disclosure, product governance for bespoke arrangements, and the quality of information provided to customers at point of sale. The FCA's insurance multi-firm reviews have highlighted deficiencies in how brokers assess and report on fair value.

Mortgage advisers operate in a sector where Consumer Duty intersects with MCOB requirements. Board packs should integrate suitability monitoring (are customers being advised onto appropriate products?), complaints data (particularly around affordability and rate switching), and consumer understanding metrics (do customers understand the implications of their mortgage choices, including what happens when fixed-rate periods end?). The FCA has flagged mortgage advice quality as a supervisory priority, making robust Consumer Duty governance a defensive necessity.