The Consumer Duty annual board report
At least once a year, your governing body must review and approve a report on the outcomes retail customers are receiving, confirm whether the firm complies with the Consumer Duty, and assess whether its strategy is consistent with it (PRIN 2A.8.4R).
What the rules require
- A report for the governing body setting out the results of the firm's outcome monitoring and any actions required (PRIN 2A.8.3R)
- Annual review and approval, a confirmation of compliance and a strategy assessment (PRIN 2A.8.4R)
- Agreed actions on risks and on poor outcomes, and any strategy changes (PRIN 2A.8.5R)
- Monitoring that shows whether products meet needs, offer fair value, whether customers are properly informed and whether they get the support they need (PRIN 2A.9.9R)
- Monitoring that identifies differences between groups of customers and any harm caused (PRIN 2A.9.10R)
- Processes to find root causes (PRIN 2A.9.11R) and appropriate action where outcomes fall short (PRIN 2A.9.12R)
A structure that works
Organised around the four outcomes, as the FCA saw in the best reports [60].
Summary and conclusion
The board's conclusion first: is the firm delivering good outcomes and complying with the Duty, and what must change.
The four outcomes
One section each for products and services, price and value, consumer understanding and consumer support: what good looks like, the evidence, the analysis and the conclusion.
Different groups of customers
Outcomes compared across groups of customers of the same product, including customers with characteristics of vulnerability.
Cross-cutting obligations
Good faith, avoiding foreseeable harm and enabling customers to pursue their financial objectives.
Harm and root causes
Where customers were harmed, why, and what was fixed. Complaints and Ombudsman decisions belong here.
Distribution chain
What you know about outcomes delivered by intermediaries and partners, and how you know it.
Actions
Each action with an owner, a date and the data that will show it worked.
Strategy
Whether the future business strategy is consistent with the Duty, and any changes agreed.
Board challenge
The questions the board asked and what it required, recorded in the minutes.
What the FCA found
First reports
The FCA reviewed the first annual board reports of 180 firms [60]. The best had dedicated sections on each of the four outcomes, good-quality MI that backed up their conclusions, analysis of different customer groups including vulnerability, a clear production process and a focus on culture.
Where reports fell short: data too weak to justify the conclusions, MI without explanation, little evidence from the distribution chain, too little on different customer groups, board challenge not evident in the minutes, and action plans without owners, timescales or the data that would show success.
Year 2
In April 2026 the FCA reported progress [61]: boards formally approving reports, most reports naming accountable owners and tracking delivery, and wider data including trend analysis, root causes and comparisons across customer groups.
It still wants more: analysis that goes beyond MI dashboards, stronger monitoring of outcomes delivered by third parties, board challenge recorded in minutes and papers, and more on consumer understanding and support, including how firms test communications and assess comprehension.
Before the board meets
- Every conclusion is backed by data, and the data is explained
- Each of the four outcomes has its own section and its own conclusion
- Customer groups are compared, including customers with characteristics of vulnerability
- Outcomes from intermediaries and partners are evidenced, not assumed
- Every action has an owner, a date and the measure that will show it worked
- The strategy is assessed against the Duty
- The minutes will record the board's questions and what it asked for
Make next year easier
The report is only as good as the year of monitoring behind it. Guardian keeps the outcome monitoring, the actions and their evidence through the year and drafts the report from them. The Consumer Duty Outcomes Engine answers the four outcome tests from live data. Or ask us to run the monitoring and write the report with you.
Questions
Short answers, with the provision each one rests on.
Is there an FCA template for the board report?
No. The FCA says its examples of good and poor practice are not intended to be prescriptive about what board reports must contain. The rules set what the governing body must do with the report (PRIN 2A.8.4R and PRIN 2A.8.5R) and what the monitoring must show (PRIN 2A.9.9R and PRIN 2A.9.10R).
How often must the board report be approved?
At least annually. The governing body must review and approve the report, confirm whether it is satisfied the firm is complying with the Duty, and assess whether its future strategy is consistent with it (PRIN 2A.8.4R).
What must the board agree when it approves the report?
Any action to address identified risks that customers may not receive good outcomes, any action to address instances where they have not, and any changes to business strategy needed to stay consistent with the Duty (PRIN 2A.8.5R).
Can a small firm produce a meaningful report?
Yes. In its review of 180 firms' first reports, the FCA found good practice from firms of all sizes, including those with fewer than 10 employees.
Board report due?
Thirty minutes on what your monitoring shows and what the report needs.