A Consumer Duty board report has to show the board, with data, whether clients are getting good outcomes. The FCA read the first annual reports from 180 firms and published what it found in December 2024. Its main complaint was not missing sections. It was reports that drew conclusions the data could not support.
What the FCA found
The FCA reviewed reports across banking, insurance, payments and consumer investments, including 55 firms with fewer than 10 staff. It listed five areas for improvement:
- Data that was not good enough to back the conclusions or give the board assurance.
- Little evidence of information shared with other firms in the distribution chain.
- Limited analysis of different outcomes for different client groups, including vulnerable clients.
- Weak evidence that the board challenged the report.
- Action plans with no timescales, owners or way to measure the result.
The better reports defined what a good outcome looked like for each of the four outcomes. They set thresholds for the management information they tracked. They backed price and value conclusions with a calculation of value against the cost of the service.
Where adviser firms fall short
Most adviser firms can say what service each client is meant to get. Fewer can show, client by client, what the client paid, what it cost to serve them and whether the service was delivered. Without that, a price and value section rests on firm averages. Averages hide the clients who pay for a service they do not receive, and the clients who cost more to serve than they pay.
The FCA’s point on client groups lands hardest here. A report that describes vulnerability support well, while the data shows fewer than half of those clients got a good outcome, is the disconnect the FCA called out.
What the evidence should look like
For each client, a board report built on evidence can answer four questions:
- What did this client pay in ongoing fees over the year?
- What did it cost the firm to serve them?
- Did they receive the service they paid for, including their review?
- Which group are they in, so outcomes can be compared across groups?
The answers then roll up into thresholds the board can monitor, and into actions with an owner and a date.
How Pillar Lens helps
Pillar Lens reads a firm’s Intelliflo data and puts every client on one line: ongoing fee, cost to serve and assets under management. It produces a quarterly board report and a Consumer Duty report from that data. Each report shows its sources and method, so the board can test the figures. The reports are decision support for the firm’s own Consumer Duty assessment. They do not certify that a firm meets its obligations, and the decisions stay with the firm.
Related: how to assess fair value on your ongoing fee.
Frequently asked questions
How often does a Consumer Duty board report have to be produced?
At least once a year. The board must review and approve it.
Does a small adviser firm need one?
Yes. The FCA's review included 55 firms with fewer than 10 staff.
What should the price and value section contain?
A comparison of what clients pay with the cost and quality of the service they receive, backed by data the board can test.
Source: FCA, Consumer Duty board reports: good practice and areas for improvement, published 11 December 2024, updated 24 February 2026.