FCA Consumer Duty outcomes monitoring review: where firms are falling short and what to fix
The FCA has published good and poor practice findings on Consumer Duty outcomes monitoring. Every retail-facing firm should read this: the regulator sets out what it expects to see and where firms are commonly falling short.
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Action required. All retail-facing firms.
The FCA has published a good and poor practice review of how firms monitor consumer outcomes under Consumer Duty. No formal document reference has been assigned to this publication. It draws on board reports, information requests, and a survey of 56 firms across sectors and sizes. The core message is blunt: collecting data is not enough. Firms must be able to explain four things: what their information tells them; how they use it to identify risks; what action they take; and whether those actions actually improved outcomes.
Where firms are going wrong
The most common structural weakness is monitoring that describes activity rather than outcomes. Some firms used operational metrics such as conversion rates or review completion rates as proxies for customer outcomes. They had not defined what a good or poor outcome looks like at each stage of the customer journey. Others set numerical thresholds for complaints, file review pass rates, or retention figures but could not explain what those thresholds were based on or what crossing them was supposed to signal.
The FCA also found firms that collected relevant management information but could not show how it fed into decisions. One firm's own board reporting noted it should keep better records of MI trends, actions, and links to customer outcomes.
Closure of the loop is another recurring failure. Some firms identified friction in customer support, agreed remedial actions, and then did not test whether those actions had worked. In one case, later evidence showed customers were still being passed between agents and complex issues were not being resolved first time, after the firm had supposedly addressed exactly those problems.
On vulnerability, some firms monitored outcomes for customers in vulnerable circumstances separately from other customers but aggregated that data rather than segmenting it by the underlying cause of vulnerability, such as health, financial resilience, or life events. That makes it harder to spot whether particular groups face distinct barriers.
What good looks like
The FCA offers concrete examples across two areas: how firms use data to drive decisions, and how governance structures support follow-through.
One firm tested rejected-applicant data to assess whether its distribution channels were reaching its target market, found that some channels were producing high levels of unsuitable applicants, and terminated two paid affiliate relationships as a result. That is outcomes monitoring driving a real commercial decision.
On governance, the FCA points to firms running a single joined-up action tracker that records issues from identification through to resolution, with named owners, target dates, and board-level oversight via a Consumer Duty Champion.
Size is not a defence
The FCA is explicit: smaller firms can use a focused set of indicators without complex systems, but they must still be able to explain what their information shows, how it helps identify harm, and what they do in response.
What to do now
There is no consultation deadline or formal follow-up action signalled in this review. Map your current monitoring framework against the gaps identified here, particularly on threshold rationale, audit trails from issue to resolution, and vulnerability segmentation. If you cannot answer the four questions set out above, start there.
