There are four Consumer Duty outcomes: products and services, price and value, consumer understanding, and consumer support. Firms must monitor whether clients actually get them, and act when they do not. On 27 July 2026 the FCA published what it found when it looked at how firms do that monitoring. Its message is plain: collecting data is not the same as showing good outcomes.
The four outcomes in plain terms
- Products and services: the service meets the needs of the clients it is sold to.
- Price and value: what the client pays is reasonable for what they receive.
- Consumer understanding: clients get information they can understand and act on.
- Consumer support: clients can get help and use the service without unreasonable barriers.
The FCA expects firms to monitor all four, not only the one that is easiest to measure.
What the FCA found in July 2026
The FCA reviewed firms across sectors and surveyed 56 firms on their strategy, data and governance for outcomes monitoring. It said that collecting data, listing metrics or reporting management information will not, by itself, show whether customers get good outcomes. A firm should be able to explain:
- What its information tells it.
- How it uses that information to find risks or issues.
- What action it takes in response.
- Whether that action improved outcomes.
The weaknesses it called out include:
- Activity metrics, such as review completion, used as a proxy for outcomes, with no definition of a good or poor outcome at each stage of the client journey.
- Thresholds with no stated basis. One firm set thresholds for complaints, file review pass rates, client retention and mortgage review engagement but could not explain what they were based on.
- Vulnerability information added up into one figure rather than split by driver, such as health, financial resilience or life events.
- Boards that review and approve reports rather than challenge them.
- Actions agreed but never tested to see if they worked.
For smaller firms, the FCA said a focused set of indicators, without complex systems or large teams, can work. What matters is that the firm can explain what the information shows and what it does in response.
Why “review completed” is not an outcome
For an adviser firm, the easy measure is the review count: how many ongoing fee clients had their annual review. The FCA treats that as an activity, not an outcome. A completed review tells you the meeting happened. It does not tell you whether the client understood their plan, whether the fee was fair for what they got, or whether a client in vulnerable circumstances got the support they needed.
Most firms already hold the facts to go further. They sit in the back office, spread across fee, activity and client records, and are rarely joined up client by client.
What outcome evidence looks like at client level
Turn each outcome into a question you can answer for every client, then compare the answers across client groups:
- Products and services: is the client on the service level their needs call for? Usually held in the client record and service agreement.
- Price and value: what did they pay in ongoing fees, and what did it cost to serve them? Usually held in fee income, activity and time records.
- Consumer understanding: was the review delivered, and is there a record the client understood it? Usually held in the review file and suitability report.
- Consumer support: are vulnerability flags recorded by driver, and was the support given? Usually held in the client record and file notes.
Then set a threshold for each measure, write down why it signals possible harm, and record what you did when a client fell outside it. That trail, from data to decision to result, is what the FCA said the stronger firms could show. The figures show you where to look. The adviser who knows the client still makes the call.
How Pillar Lens helps
Pillar Lens reads a firm’s Intelliflo data and puts every client on one line: ongoing fee, allocated cost to serve and assets under management. It shows which clients cost more to serve than they pay and where service records are missing. Lens is decision support for the firm’s own Consumer Duty assessment. It does not certify that a firm meets its obligations, and the decisions stay with the firm. Pillar gives no regulated advice.
Related: how to assess fair value on your ongoing fee and what a Consumer Duty board report needs to hold. Where reviews are falling behind, see how the client review service works.
Frequently asked questions
What are the four Consumer Duty outcomes?
Products and services, price and value, consumer understanding, and consumer support. Firms must monitor all four.
Does a small adviser firm need to monitor Consumer Duty outcomes?
Yes. The FCA said smaller firms can use a focused set of indicators without complex systems, as long as they can explain what the information shows and what they do about it.
Is the number of annual reviews completed a good outcome measure?
Not on its own. In July 2026 the FCA named review completion as an activity metric that some firms used in place of a defined outcome.
Sources: FCA, Outcomes monitoring: good practice and areas for improvement, published 27 July 2026; FCA, Consumer Duty. Both read 13 October 2026. General information for regulated firms, not regulatory or legal advice.