The Consumer Duty has undoubtedly enhanced the standards that a firm needs to deliver. It is designed to be a proactive mandate for delivering good outcomes to clients.
If we consider all the work that firms have undertaken to change the way they operate over the past two years, the annual Board Report becomes fundamental in demonstrating a firm's progress and commitment to this Duty.
It should not be seen as merely a compliance exercise. Instead, it is a strategic document that evidences your firm's culture, identifies areas of good practice, and just as importantly, highlights and addresses potential areas of harm. It is effectively a roadmap for the business.
What does the FCA Expect?
Evidence-based assessments were a key focus of the FCA’s 2024 Consumer Duty Board Report review. If a firm claims to be delivering good outcomes, it must be able to demonstrate how. This includes providing relevant Management Information (MI) that clearly supports and evidences those outcomes.
The report should reflect a culture that places consumer needs at its core and is championed by senior leadership. A top-down commitment is essential to embedding Consumer Duty principles throughout the organisation.
The FCA will also look for evidence of robust discussion and challenge at the board level. This scrutiny should be clearly documented either within the report itself or in supporting materials such as board meeting minutes.
Finally, the report must go beyond simply identifying issues. It should include a clear and actionable plan, with responsibilities assigned to specific individuals. This action plan must then be followed up in the next annual Board Report to track and demonstrate tangible progress.
Keeping on Track
The Board Reports reviewed by the FCA in 2024 relied heavily on high-level MI. This needs to change. We’ve created a detailed PDF guide that sets out what good MI looks like across the four outcomes of the Duty:
- Products and Services: Is your proposition delivering on client needs?
- Price and Value: Are clients getting fair value for money?
- Consumer Understanding: Are your communications driving real comprehension?
- Consumer Support: Are you offering support that meets the needs of all client types?
Fill in the form below to download the detailed guide:
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Each section includes MI examples, analysis and commentary from Thistle Initiatives experts, and common pitfalls to avoid. You’ll also find guidance on how to use complaints data, vulnerable client insights, and client feedback to strengthen your report.
Remember: Being 'Consumer Duty Ready' is an ongoing journey, not a one-off project. Your annual Board Report is a journey that over time will show the steps a firm has taken to challenge themselves to continuously put their clients first.
How Thistle Initiatives Can Help
Need help with your Consumer Duty Board Report? We’re offering a free review to check whether your draft meets FCA expectations. You’ll get clear, practical feedback on your use of MI, evidence of outcomes, and any gaps to address.
Get in touch at info@thistleinitiatives.co.uk or call 020 7436 0630 to speak with our team.
Meet the Expert
Paul Caine, Associate Director 
As an Associate Director at Thistle Initiatives and a dedicated member of the Chartered Insurance Institute (CII), Paul consistently demonstrates his commitment to upholding the highest standards of professionalism and expertise in the financial industry. His involvement in Section 166 projects underscores his dedication to enhancing the industry's integrity and regulatory compliance.
Specialising in pensions and investments, Paul possesses a profound understanding of regulatory compliance across various sectors. His established track record is a testament to his ability to deliver tangible benefits to his clients.