Consumer Duty board report: template and FCA expectations

This guide is for compliance leads, owners and governing-body members at UK advice firms writing the annual report. The FCA reviewed the first year of reports from 180 firms, added guidance for smaller firms on 24 February 2026, and set out four areas to improve on 16 April 2026 ahead of the third cycle. The sections below cover who must prepare the report, what it must contain, when it is due, what the FCA looks for, the data behind it, and a template to adapt.

What is a Consumer Duty board report?

A Consumer Duty board report is the report PRIN 2A.8.3R requires a firm to prepare for its governing body: the results of its monitoring under PRIN 2A.9 and any actions required as a result of that monitoring.

The FCA’s own page calls it the annual board report. FG22/5, the FCA’s final non-Handbook guidance for firms on the Consumer Duty, describes the same duty in words: a firm’s board, or equivalent governing body, should review and approve an assessment of whether the firm is delivering good outcomes for its customers, at least annually (FG22/5 10.11).

Two documents govern the report. PRIN 2A.8 of the FCA Handbook holds the binding rules, and FG22/5 explains how the FCA reads them; PRIN 2A.1.12G tells firms to read FG22/5 as a guide to the FCA’s view of how the Consumer Duty might be complied with. The rules set the duty and FG22/5 explains it; neither sets a form.

Who must prepare a Consumer Duty board report?

The duty applies to a firm’s retail market business, including existing and closed products (PRIN 3.2.6R(1)), and in a distribution chain only where the firm is responsible for determining or materially influencing retail customer outcomes (PRIN 3.2.7R). It also covers communicating or approving financial promotions likely to reach retail customers (PRIN 3.2.6R(2)).

PRIN 2A.8.3R then requires the firm to prepare the report, and FG22/5 10.11 addresses it to “a firm’s board, or equivalent governing body”. The FCA tells smaller firms that, in the absence of a Board, they should think about how to bring independence and objectivity into their assessment, for example through a critical friend who can provide support and challenge.

The FCA’s review of the first year of reports adds that smaller firms often lack formal committees or a board, and that clear documentation of who is responsible for embedding and monitoring the Duty supports accountability. We suggest the report names the body or person that approved it.

What must the board report contain?

PRIN 2A.8.3R requires the report to set out the results of the firm’s monitoring under PRIN 2A.9 and any actions required as a result. FG22/5 10.12 says the assessment should include three things:

• the results of the monitoring the firm has undertaken to assess whether products and services are delivering expected outcomes in line with the Duty, any evidence of poor outcomes, including whether any group of customers is receiving worse outcomes compared to another group, and an evaluation of the impact and the root cause;
• an overview of the actions taken to address any risks or issues;
• how the firm’s future business strategy is consistent with acting to deliver good outcomes under the Duty.

At least annually, the governing body must do three things (PRIN 2A.8.4R):

• review and approve the firm’s report on the outcomes being received by retail customers;
• confirm whether it is satisfied that the firm is complying with its obligations under the Consumer Duty;
• assess whether the firm’s future business strategy is consistent with its obligations under the Consumer Duty.

When it approves that report, the governing body must also agree three things (PRIN 2A.8.5R):

• any action required to address any identified risk that retail customers may not receive good outcomes;
• any action required to address any identified instance where retail customers have not received good outcomes;
• any amendments to the firm’s business strategy to ensure that it remains consistent with meeting the firm’s obligations under the Consumer Duty.

FG22/5 10.13 repeats the same three agreements as a step taken before sign-off, and the FCA’s review says it should be clear from each report that these steps have been followed. The report itself is evidence: FG22/5 10.14 says the assessment will be part of the evidence the FCA uses to assess compliance, and that it expects to be provided on request with the report and the management information behind it.

No official form follows from those rules. The FCA states that its rules do not set a specific template for the Board report and that it is for individual firms to determine what is appropriate for them, and that length and detail will likely depend on the nature and extent of the firm’s business activities and the impact they have on consumer outcomes. Firms do not send the report to the FCA, but the FCA expects firms to be able to provide it if asked.

Which outcomes does the report cover?

The report covers all four retail customer outcomes, and PRIN 2A.9.9R says the monitoring behind them must enable the firm to determine at least four things, one under each outcome.

The four sections above are four of the twelve areas the FCA rated when it read 180 reports, and they are the four outcomes explained in Consumer Duty evidence, which also sets out what to hold behind each determination.

When is the Consumer Duty board report due?

The first report was due by 31 July 2024 for firms with new and existing products and services, and PRIN 2A.8.4R then requires a report at least annually.

The rules give no fixed date for later years: PRIN 2A.8.4R says at least annually, and the FCA’s own page for firms gives no later date. On 16 April 2026 the FCA wrote that the third cycle of board reports was on the horizon, so firms should treat the report as an annual event in the calendar rather than a date issued by the regulator.

One governance expectation did change. From 27 February 2025 the FCA no longer expects firms to have a Duty champion, although firms can keep the role, and it said it would amend the references to Board champions in FG22/5 in due course. FG22/5 10.10 still carries the original expectation today. The FCA’s April 2026 blog adds that many firms chose to keep their champion.

The FCA has also consulted on changing these rules. CP26/23(29 June 2026) proposes that Duty board reporting need not be a stand-alone report and can be built into a firm’s other board reporting, still at least annually. The consultation closed on 18 September 2026 and the FCA expects to make any new rules in Q1 2027. Until then, PRIN 2A.8.3R to 2A.8.5R apply as written.

What does the FCA look for in a board report?

The FCA read the first annual reports from 180 firms, including 55 smaller firms, and published five aspects of good reports and five areas for improvement. The two columns below are those two lists, not matched pairs.

The FCA labels these examples as illustrative and says they are not intended to be prescriptive in terms of what board reports must contain. What it asks for in the reports themselves is clearer: good reports supported their conclusions with good quality management information, considered different groups of customers including those with characteristics of vulnerability, and showed the process that produced them.

For the next cycle the FCA named four areas to work on:

• clearly link data to customer outcomes, with analysis that goes beyond management information dashboards and draws conclusions;
• monitor outcomes delivered by third parties, especially where the firm relies on intermediaries or outsourcing partners;
• evidence meaningful board challenge in minutes and papers, including the questions asked and the follow-up actions requested;
• deepen the assessment of consumer understanding and support, evidencing how the firm tests communications, assesses consumer comprehension, and responds where customer behaviour shows misunderstanding or friction.

Compared with year 1, the year-2 reports showed progress: boards formally reviewed and approved them with an explicit confirmation, most reports named accountable owners for actions and tracked delivery, and firms drew on a wider range of quantitative and qualitative data (FCA, 16 April 2026).

What data should feed the report?

PRIN 2A.9.8R requires a firm to regularly monitor the outcomes retail customers receive from three sources: the products the firm manufactures or distributes, the communications the firm has with retail customers, and the customer support the firm provides.

That monitoring must also let the firm identify three things (PRIN 2A.9.10R), and each one is a line a reader of the report should be able to find:

• whether the firm is complying with Principle 12, the rule that a firm must act to deliver good outcomes for retail customers (PRIN 2.1.1R), and the cross-cutting obligations in PRIN 2A.2: act in good faith, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives;
• whether, for any product the firm manufactures or distributes, a group of retail customers experiences different outcomes from another group of retail customers on the same product;
• whether any retail customers have suffered harm as a result of the firm’s acts or omissions.

The specific monitoring firms already do under each outcome counts towards this: PRIN 2A.9.5G says firms may use the information gathered through those processes when preparing the report required under PRIN 2A.8.3R. FG22/5 adds four points about the data behind it. Management information should suit the nature, scale and complexity of the business (11.19). It should go beyond complaints data (11.22). Some monitoring covers all customers, while other types, such as file reviews, use a risk-based sample (11.23). And where a firm outsources, it needs arrangements with the provider to capture the data needed to monitor outcomes (11.29). Our guide to the FCA outsourcing rules (SYSC 8) covers checking a supplier that holds this monitoring data.

Records sit beside the data. FG22/5 11.26 says there is no prescribed format for evidencing monitoring, but expects firms to keep records that can be provided on request, and 11.27 expects records of the issues identified and the action taken. PRIN 2A.9.15G points firms at SYSC 3 and SYSC 9 for the detail, and financial adviser record keeping obligations covers how long advice records are kept in practice.

Producing the report can be quicker when that data already sits in connected systems instead of being collected by hand each year. AI software for financial advisers under Consumer Duty covers the wider duties software has to serve, and software for financial advisers shows what we build to hold it.

What does a Consumer Duty board report template look like?

This is a starting point to adapt, not an FCA-approved form: it maps PRIN 2A.8.3R to 2A.8.5R, FG22/5 10.11 to 10.14 and the FCA’s review findings into eleven sections. Replace the bracketed prompts, delete what does not apply, and keep the version the governing body approved.

1. Scope and basis. [Products, services and customer groups covered; the period reviewed; the provisions the report is prepared under.]
2. Executive summary. [Whether retail customers received good outcomes overall, the main risks, and what the governing body is asked to approve.]
3. Products and services. [Monitoring results against the target market, and any product not serving the customers it was designed for.]
4. Price and value. [Fair value monitoring results, and the action taken on products identified as not providing fair value.]
5. Consumer understanding. [What the testing of communications shows about whether customers were equipped to make properly informed decisions.]
6. Consumer support. [What response, complaint and switching data shows about the support customers actually receive.]
7. Differences between customer groups. [Whether any group received worse outcomes than another group, with the impact and the root cause (FG22/5 10.12).]
8. Poor outcomes and harm. [Evidence of poor outcomes, the harm identified, the root cause process and the action taken (PRIN 2A.9.11R and 2A.9.12R).]
9. Actions agreed.[The actions agreed under PRIN 2A.8.5R, each with an owner and a timescale, and the status of last year’s actions.]
10. Future business strategy.[How the strategy stays consistent with the firm’s obligations under the Consumer Duty (PRIN 2A.8.4R(3)).]
11. Record of the meeting. [Date of approval, the confirmation of compliance, the challenge raised by the governing body, and the minute reference.]

Frequently asked questions

Sources

1. FCA Handbook PRIN 2A.8 (governing body report), last updated 26 June 2026
2. FCA Handbook PRIN 2A.9 (monitoring of consumer outcomes)
3. FCA Handbook PRIN 3.2 (scope of the Consumer Duty)
4. FCA Handbook PRIN 2.1.1R (the Principles for Businesses, including Principle 12)
5. FCA Handbook PRIN 2A.2 (cross-cutting obligations)
6. FCA Handbook PRIN 2A.1 (application and purpose), paragraph 2A.1.12G
7. FCA, Consumer Duty information for firms (last updated 5 August 2026)
8. FCA, Consumer Duty board reports: good practice and areas for improvement (published 11 December 2024, smaller-firm insight added 24 February 2026, last updated 9 March 2026)
9. FCA, Year 2 Consumer Duty Board Reports: progress and what comes next (16 April 2026)
10. FCA, FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty (PDF)
11. FCA, PS22/9: A new Consumer Duty (published 27 July 2022)
12. FCA, CP26/23: Consumer Duty: scope and proportionality (29 June 2026; consultation closed 18 September 2026)