Consumer Duty outcomes testing: how to evidence good outcomes

Outcomes testing is how a firm checks whether its customers are getting good outcomes under the Consumer Duty, rather than assuming it from a completed process. The rules call this monitoring. PRIN 2A.9.8R says a firm "must regularly monitor the outcomes" its retail customers receive, drawing on information about its products, its communications and the customer support it provides.

If you are new to the four outcomes themselves, our FCA Consumer Duty overview explains them. This article covers the harder question: how you show, with evidence, that the outcomes are being delivered.

Monitoring has to answer specific questions

The rules set out what monitoring must be able to tell you. Under PRIN 2A.9, monitoring must enable a firm to determine at least whether customers are sold products designed for their needs, whether products offer fair value, whether customers have the information to make decisions, and whether they receive the support they need.

PRIN 2A.9.10R adds that monitoring must also identify whether outcomes differ between customer groups for the same product, and any harm caused by the firm's acts or omissions. A dashboard that cannot answer those questions is reporting activity, not testing outcomes.

What the FCA found on testing

On 27 July 2026 the FCA published Outcomes monitoring: good practice and areas for improvement. The review used board reports and responses to information requests across sectors and sizes of firm, and included a survey of 56 firms. It covered three areas: strategy and framework; data, management information (MI) and testing; and governance, oversight and culture. It sits alongside the rest of the FCA's Consumer Duty material, and its testing findings are the most useful part for anyone building a test.

The good practice was concrete. One firm tested rejected-applicant data, found that some channels were producing unsuitable applicants, and "ended 2 paid affiliate relationships as a result." That is a test with a consequence. Another firm used a financial vulnerability indicator and reviewed customers above its threshold individually.

The weaknesses were about the link between data and decisions. Firms collected MI but did not clearly show how it led to decisions or better outcomes. Thresholds were often set without a clear rationale. Some firms relied on lagging indicators and lacked audit trails from issue to action to outcome, and some remedies were never tested.

How to design an outcomes test

1. Define a good outcome for each product and stage. The FCA's good practice is to define what good looks like for each key product and link it to the customer journey, from joining and using the service to leaving. One broad statement covering every product is weaker.
2. Test the outcome, not the activity. Conversion rates and review completion are operational measures. The FCA found some firms used them as a proxy for outcomes without defining what a good or poor outcome looks like at each stage.
3. Set the threshold and record why. Write down why the threshold sits where it does. The FCA's good practice is to set targets from past performance, keep them challenging through governance and review them at least once a year.
4. Break the results down. Averages can hide the customers who are worst off, so split results by customer group. Where vulnerability is relevant, break it down by driver. Our guide to the FCA's drivers of vulnerability sets out the four drivers to use.
5. Attach a trigger to a review. The FCA's examples of proportionate monitoring include a simple MI tracker with triggers. A result that crosses a trigger should start a targeted review, not wait for the next annual report.
6. Record the action, the owner and the result. The FCA's good practice is an integrated action tracker with named owners, target dates and status. The test is then whether the change improved the outcome, which is the step firms most often skip.

The table below shows what each stage should leave on file.

Root causes and the duty to act

Finding a poor outcome is only half the job. PRIN 2A.9.11R requires processes to identify the root causes of any failure to deliver the outcomes. Under PRIN 2A.9.12R, where a firm identifies a problem, it "must take appropriate action to address the situation." The FCA found that firms often showed the actions taken but not the root cause, or whether the action worked. A test should therefore end with one question: did the outcome change?

What proportionate testing looks like

The FCA says: "We expect all firms to deliver good outcomes for their customers, however big or small they are." Smaller firms can use a focused set of indicators, provided they can explain what the information shows, how it identifies harm and what action follows. The examples include plain-language outcome descriptions for key journey stages, a small set of indicators, a weekly case review and a simple log of issues and actions. Our Consumer Duty compliance checklist for small firms turns these into steps.

Where test results go

Test results feed the annual board report. Under PRIN 2A.8.3R, a firm must prepare a report for its governing body setting out the results of its monitoring under PRIN 2A.9 and any actions required. The governing body must review and approve it at least annually. We cover what the report should contain in the annual board report guide.

How MEMA can help

MEMA Consultants helps firms define outcomes, set thresholds and build tests that a board can challenge. Start with our Consumer Duty service. If you want a quick view of where the gaps are, our Consumer Duty diagnostic is a useful first step.