In this Guide…
Consumer Duty is no longer about principles alone. Firms now need evidence: clear, repeatable ways to show how customer outcomes are monitored, challenged, and improved. This post looks at how one FCA-regulated insurer structured that process in practice, and the five components other firms can learn from.
Most pages on the first page of Google for “consumer duty outcomes” will tell you what the four outcomes are. None will tell you what an evidence pack for them actually contains, the best way to build one, or how to turn dashboard numbers into defensible answers to the regulator’s questions
The FCA has signalled it will scrutinise the second round of board reports more rigorously than the first. “We discussed the outcomes” is no longer adequate — firms need to evidence the deliberation, not just the conclusion.
One insurer we work with has turned the four outcomes into a repeatable process. A standing Customer Conduct Committee, a monthly outcome dashboard, a survey-to-outcome map, and a culture summed up by their Head of Risk & Compliance in five words: “if it’s not written down, nothing’s happened.”
This post breaks down how it works in practice: the committee structure, the dashboard, why comments matter more than scores, and a five-part checklist other FCA-regulated firms can use.
The committee that owns the four Consumer Duty outcomes
A large insurer we work with produces their Consumer Duty evidence pack from a standing Customer Conduct Committee that meets monthly, chaired deliberately by the Head of Operations, not the Head of Risk & Compliance.
Most firms put a compliance lead in the chair because Consumer Duty is a regulatory programme.
Our client did the opposite. Putting Operations in the chair signals internally that this is business-as-usual customer governance, not an audit ceremony.
Their Head of Risk & Compliance, attends rather than chairs, and the committee is positioned as a customer body that compliance is part of, rather than a compliance forum that customer-facing teams are summoned to.
Standing attendance covers the four outcomes between them: compliance, complaints, CX, and marketing all in the room every month. Marketing’s presence is important: Marketing owns the customer-facing language that touches “consumer understanding” most directly, and you’ll see why in the worked example later.
The committee structure reflects a broader sector shift. Consumer Duty has absorbed customer-experience expertise into compliance, not the other way round. Firms increasingly need compliance leaders who have spent years close to real customer outcomes, not just regulatory interpretation
Cadence is monthly, not quarterly. A monthly drumbeat means deliberations and decisions are recent enough to be evidenced cleanly when the board pack lands.
The dashboard: a monthly score per Consumer Duty outcome
This insurer’s Consumer Duty MI is structured around the four outcomes themselves. Survey questions are written to evidence specific outcomes, and each outcome carries a percentage score. The committee tracks month-on-month movement against each.
Survey-to-outcome mapping is the foundation. The questions aren’t generic “rate your experience” prompts. They’re authored to evidence a specific outcome, so the score in the dashboard is defensible because the question is defensible.
We work with all our FCA-regulated customers to design survey questions that map cleanly to each of the four outcomes, so the score in the dashboard isn’t a generic CSAT number but a signal you can use to drive operational work.
One score per outcome, tracked month over month. The committee opens its meeting on the dashboard. Score movement is the trigger for discussion. The dashboard’s job is not to be the board pack — it’s what the board pack is built from. The board pack pulls from the dashboard; the dashboard pulls from the survey infrastructure underneath.
But the scores aren’t the evidence, the comments are
The percentage score per outcome is “a really quick guide.”
The actionable material, and the auditable evidence, sits in the qualitative comments underneath each outcome. Treating the score line as the answer is the most common Consumer Duty mistake we see in financial-services firms.
The score is a heat indicator. The comment is the evidence. When the FCA — or an internal auditor — asks “what did your customers say about consumer understanding this year?”, the answer isn’t a percentage. It’s a treasure trove of customer language, categorised and quickly findable.
This is where most Consumer Duty MI falls down. Firms build dashboards around scores because scores are easy to summarise upwards.
But a board report that contains percentages without comments is a board report that won’t stand up to scrutiny. If your only answer to the regulator’s question is “the score went up two points,” and you can’t tell them what customers were actually saying, you’re on shaky ground.
Sometimes when we start a new client engagment, we hear the totally reasonable question, “won’t the volume of comments be unmanageable?”
A year’s worth of comments per outcome, grouped by topic, is exactly the audit artefact the regulator wants.
The work isn’t in collecting fewer of them; it’s in making them findable and themeable. That’s the role a good VoC partner plays: Making the audit question “what did your customers say about consumer understanding?” return a real answer with the verbatim material attached, rather than a number with a footnote.
Five things any FCA-regulated firm can lift from this
Strip away the insurance context and the structure is transferable: five core elements that any FCA-regulated firm can replicate, regardless of sector, size, or technology stack.
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A standing Customer Conduct Committee, not a quarterly compliance meeting. Monthly cadence.Not a special meeting called when the board pack is due.
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The chair is from the customer side of the business, not compliance. Head of Operations, Head of CX, Head of Service, not Head of Risk. The chair choice signals “this is how we run the business,” not “this is how we satisfy the regulator.”
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Standing attendance from compliance, complaints, CX, and marketing. Marketing is the one most firms forget. Marketing owns the customer-facing language that touches “consumer understanding” the most directly, and excluding them means the deliberation about renewal letters, claim communications, and policy documents happens somewhere else.
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A survey-to-outcome map, not a generic CSAT instrument. Survey questions written to evidence specific outcomes, not lifted from an off-the-shelf bank. The score line is only defensible if the question underneath it is.
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A comment-first reporting line into the board pack. Scores in the dashboard for trend; verbatim themes in the report for evidence. The two layers do different jobs and the second one is the one the regulator actually asks about.
There is a hard cost sitting behind all of this. A Financial Ombudsman case costs £650 regardless of the outcome. If the case is closed because the customer has not provided information, it can still come back later — and trigger another £650 — if that information eventually arrives.
The alternative to comment-led evidence is not “saving money on reporting infrastructure”. It is being unable to answer the follow-up questions, then paying each time the customer escalates because the evidence was not good enough the first time.
For more on building a voice-of-customer programme that supports Consumer Duty work specifically, our practical guide to VoC for financial services covers five things to lift.
What Consumer Duty’s second board cycle will reward
Consumer Duty’s second board reporting cycle will reward firms that can show how decisions were made, not firms that have simply written a longer report. The example structure our client uses is one way to do that, but the underlying principle is the most important part: if it isn’t written down, nothing has happened. The regulator is likely to work from the same assumption.
The work to improve Consumer Duty reporting is mostly governance and survey design, not new technology — but if you’re rebuilding your Consumer Duty MI ahead of this year’s board pack, talk to us about how survey-to-outcome mapping works for FCA-regulated firms. (See also our Covéa case study, for even more about how we support firms in your industry)
Build a Consumer Duty evidence pack the FCA can't pick apart.
If your Consumer Duty MI is score-led and your board pack can't answer the regulator's follow-up question, you need better survey design, not longer or smarter reports. We help FCA-regulated firms map survey questions cleanly to each of the four outcomes and turn a year's worth of verbatim comments into the audit artefact the second board cycle is going to ask for.
Darren Wake
Darren Wake leads Customer Success at CustomerSure, where he helps clients act on feedback in ways that improve retention, increase revenue, and reduce customer effort. With a background in marketing, research, and experience design, he’s worked with teams across sectors to align internal processes with what matters most to customers. Known for his practical, plain-speaking approach, Darren helps organisations keep things simple, focus on the essentials, and deliver measurable improvements.
