Consumer Duty outcomes: the evidence advice firms need

This guide is for compliance leads and owners of UK financial advice firms authorised by the Financial Conduct Authority (FCA). On 27 July 2026 the FCA published a review of outcomes monitoring which says that collecting data or reporting management information will not, by itself, show whether customers are receiving good outcomes. Building Filyst, our case management product for immigration firms, taught us that the strongest evidence is a record the system writes as the work happens. The sections cover each part of the Duty, the evidence we suggest holding for it, what monitoring must show and what may change.

What are the Consumer Duty outcomes?

The Consumer Duty outcomes are the four areas in which an FCA-regulated firm must deliver good outcomes for retail customers: products and services, price and value, consumer understanding and consumer support. PRIN 2A.1.10G(3) of the FCA Handbooksays the rules at PRIN 2A.3 to PRIN 2A.6 set out firms’ key obligations in those four areas.

The Duty has three layers, each in the Principles for Businesses sourcebook (PRIN) of the FCA Handbook:

• Principle 12, the one-sentence duty in PRIN 2.1.1R;
• three cross-cutting obligations, often called the cross-cutting rules, in PRIN 2A.2;
• four retail customer outcomes, in PRIN 2A.3 to PRIN 2A.6.

PRIN 2A is the Handbook chapter that holds the detailed rules. A retail customer includes a prospective customer (PRIN 2A.1.5G), and a product includes a service (PRIN 2A.1.4G), so an advice service is a product for the Duty. The FCA’s non-Handbook guidance on the Duty is FG22/5, which PRIN 2A.1.12G says firms should read as a guide to the FCA’s view of how the Duty might be complied with.

Who does the Consumer Duty apply to, and since when?

The Consumer Duty applies to a firm’s retail market business, including existing products and closed products (PRIN 3.2.6R(1)). It came into force on 31 July 2023 for products and services open to sale or renewal, and on 31 July 2024for closed products and services, according to the FCA’s Dear CEO letter of 16 May 2024.

Four scope points matter to an advice firm:

• In a distribution chain, the Duty applies only to the extent a firm is responsible for determining or materially influencing retail customer outcomes (PRIN 3.2.7R).
• Principles 6 and 7 do not apply where the Duty applies (PRIN 3.2.10R).
• Services to professional clients are an example of activities where Principles 6 and 7, not the Duty, may apply (PRIN 3.2.11G).
• A closed product is one with existing customers who took out a contract before 31 July 2023, and which has not been marketed or distributed, including by renewal, on or after that date (the letter’s Annex 1).

Every rule is read against one standard: what could reasonably be expected of a prudent firm carrying on the same activity for the same product, taking account of the needs and characteristics of its retail customers (PRIN 2A.7.1R).

What does Principle 12 require, and what evidence shows it?

Principle 12 reads: “A firm must act to deliver good outcomes for retail customers” (PRIN 2.1.1R). It applies to every firm and activity within the Duty’s scope.

The cross-cutting obligations exhaust what Principle 12 requires (PRIN 2A.2.26R), and the outcome rules help define it without exhausting it (PRIN 2A.2.28G). Evidence for Principle 12 is therefore the evidence for the three rules and four outcomes below. Monitoring must also identify whether the firm is complying with Principle 12 and the cross-cutting obligations (PRIN 2A.9.10R(1)).

Evidence to hold (our suggestion):a short statement of what a good outcome looks like for each service the firm offers, and the monitoring results that test it. The FCA’s 2026 review gives one firm’s approach as good practice: it defined good outcomes for each key product at stages such as joining, using the service and leaving.

What are the three cross-cutting rules, and what evidence fits each?

The three cross-cutting rules require a firm to act in good faith, avoid causing foreseeable harm, and enable and support retail customers to pursue their financial objectives (PRIN 2A.2). They apply at all stages of the customer journey and through the whole lifecycle of a product (PRIN 2A.2.23G).

Act in good faith (PRIN 2A.2.1R)

A firm must act in good faith towards retail customers. Good faith is a standard of honesty, fair and open dealing and acting consistently with retail customers’ reasonable expectations (PRIN 2A.2.2R). If a firm finds, through complaints, monitoring or any other source, that customers suffered foreseeable harm from its acts or omissions, it must take appropriate action to rectify the situation, including redress where appropriate (PRIN 2A.2.5R).

Evidence to hold (our suggestion): a complaints log with the root cause of each complaint, and a record of each harm found, the action taken and any redress decision.

Avoid causing foreseeable harm (PRIN 2A.2.8R)

A firm must avoid causing foreseeable harm to retail customers, by act or omission (PRIN 2A.2.9R). The guidance at PRIN 2A.2.10G includes updating information about a product or updating investment advice, and making sure customers face no unreasonable barriers when they want to switch or complain.

Evidence to hold (our suggestion):a list of the harms the firm can foresee for each service, and a dated record of what changed when a product, a provider or a client’s circumstances changed.

Enable and support customers to pursue their financial objectives (PRIN 2A.2.14R)

A firm must enable and support retail customers to pursue their financial objectives. A firm providing advisory or discretionary services can rely on the objectives customers disclose, unless it knows or could reasonably be expected to know the information is manifestly out of date, inaccurate or incomplete (PRIN 2A.2.17G).

Evidence to hold (our suggestion):each client’s recorded objectives with the date they were collected and last confirmed.

Outcome 1, products and services: what evidence shows the service fits its target market?

The products and services outcome requires a distributor to keep distribution arrangements, for each product it distributes, that avoid foreseeable harm, support proper management of conflicts of interest and take account of the target market’s needs (PRIN 2A.3.14R). The target market is the group of customers a product or service is designed for.

A distributor must regularly review those arrangements and verify that it is only distributing each product to the identified target market (PRIN 2A.3.19R). A manufacturer must specify the target market and review its products regularly (PRIN 2A.3.4R and 2A.3.7R). Monitoring must determine whether customers are being, or have been, sold products designed to meet their needs, characteristics and objectives (PRIN 2A.9.9R(1)).

PRIN 2A.3 does not apply to a firm subject to PROD 3, PROD 4 or PROD 7 for products within the scope of the relevant PROD chapter, or to a bespoke insurance contract (PRIN 2A.3.24R). Other exceptions, including funds being wound up, are in PRIN 2A.3.

Evidence to hold (our suggestion): a target market statement for each advice service, file reviews that compare the client with that target market, and the dated record of each distribution review.

Outcome 2, price and value: what evidence shows fair value?

The price and value outcome requires products to provide fair value. Value is the relationship between the amount a retail customer pays and the benefits they can reasonably expect, and fair value means the amount paid is reasonable relative to those benefits (PRIN 2A.4.1R).

A manufacturer must carry out a value assessment and review it regularly (PRIN 2A.4.2R). A distributor must not distribute a product unless its distribution arrangements are consistent with the product providing fair value (PRIN 2A.4.16R). A firm must not rely on individual customers’ views of value in place of its own assessment (PRIN 2A.4.20R). Monitoring must determine whether products provide fair value and whether action has been taken on those that do not (PRIN 2A.9.9R(2)).

PRIN 2A.4 does not apply to three cases (PRIN 2A.4.32R(1)):

• a firm that manufactures or distributes a non-investment insurance product or a legacy non-investment insurance product;
• a firm that manufactures or distributes a funeral plan product subject to PROD 7;
• an authorised fund manager for products subject to the listed COLL value rules.

Evidence to hold (our suggestion): the value assessment and its review dates, and a comparison of the charges each client group paid with the service it received. The Consumer Duty fair value assessment post sets out what that assessment contains.

Outcome 3, consumer understanding: what evidence shows clients understood?

The consumer understanding outcome requires a firm’s communications to meet customers’ information needs, be likely to be understood, and equip them to make effective, timely and properly informed decisions (PRIN 2A.5.3R). It applies to all communications, verbal, visual or written, through any channel (PRIN 2A.5.1R).

A firm must tailor communications to the customer’s characteristics, the product’s complexity, the channel and its own role, including whether it is giving regulated advice (PRIN 2A.5.8R). In one-to-one conversations, it must where appropriate ask whether the customer understands and has further questions (PRIN 2A.5.9R). Where appropriate, it must test communications before sending them and monitor their impact afterwards (PRIN 2A.5.10R). Monitoring must determine whether customers are equipped to make effective, timely and properly informed decisions (PRIN 2A.9.9R(3)).

Evidence to hold (our suggestion): test results for key documents such as suitability reports and fee disclosures, meeting notes that record the understanding check, and response rates to letters that ask clients to act. PRIN 2A.5.13G(2) says a notably lower response than expected suggests a communication has not been understood.

Outcome 4, consumer support: what evidence shows support works?

The consumer support outcome requires a firm to design and deliver support that meets customers’ needs, lets them use the product as reasonably anticipated, includes appropriate friction to mitigate harm, and puts no unreasonable barriers in their way (PRIN 2A.6.2R).

PRIN 2A.6.2R(4) names seven moments where a customer must not face unreasonable barriers, including unreasonable additional costs:

• making general enquiries or requests;
• amending or switching the product;
• transferring to a new product provider;
• accessing a benefit the product is intended to provide;
• submitting a claim;
• making a complaint;
• cancelling a contract or otherwise ending the relationship with the firm.

PRIN 2A.6.4G gives disproportionately longer call waiting times to cancel than to buy as an example of an unreasonable delay. A firm must give a person authorised to act for the customer, such as an attorney, the same level of support as the customer (PRIN 2A.6.5R). Monitoring must determine whether customers receive the support they need (PRIN 2A.9.9R(4)).

Evidence to hold (our suggestion): response times for enquiries, the time taken to transfer or cancel compared with the time taken to start, and complaint data by cause.

What must Consumer Duty outcomes monitoring show?

A firm must regularly monitor the outcomes retail customers receive from its products, its communications and its customer support (PRIN 2A.9.8R). The monitoring must enable it to determine at least the four things in the table (PRIN 2A.9.9R), one for each outcome.

Monitoring must also enable the firm to identify three things (PRIN 2A.9.10R):

• whether it is complying with Principle 12 and the cross-cutting obligations;
• whether any group of customers of a product is getting different outcomes from another group of the same product;
• whether any customers have suffered harm from the firm’s acts or omissions.

A firm must have processes to find the root causes of any failure to deliver the outcomes (PRIN 2A.9.11R), and must take appropriate action where outcomes are not met, a group is getting worse outcomes or it is not complying with Principle 12 (PRIN 2A.9.12R). A firm in a distribution chain must notify the FCA if it becomes aware that another firm in the chain is not, or may not be, complying with the Duty (PRIN 2A.9.17R).

The FCA’s outcomes monitoring review of 27 July 2026 says firms should be able to explain four things: what their information tells them, how they use it to identify risks or issues, what action they take, and how they consider whether those actions improved outcomes. It says smaller firms could use a focused set of indicators without complex systems, and gives complaints, customer feedback, missed service standards and file checks as the indicators some smaller firms used.

The Duty sets no record format. PRIN 2A.9.15G says SYSC 3 and SYSC 9 hold the high-level record-keeping requirements, and firms decide what records they need to keep for the Duty. Record keeping for financial advisers covers how long advice records are kept.

How does the evidence reach the board?

A firm must prepare a report for its governing body setting out the results of its monitoring under PRIN 2A.9 and any actions required (PRIN 2A.8.3R). The governing body, the firm’s board or equivalent, must review and approve that report at least annually (PRIN 2A.8.4R). The monitoring evidence above is the raw material for this governing body report, often called the board report; the Consumer Duty board report post covers what the board must confirm and agree.

Is the Consumer Duty changing?

The FCA consulted on changes in CP26/23, “Consumer Duty: scope and proportionality”, which opened on 29 June 2026 and closed on 18 September 2026. Its consultation page, last updated on 21 September 2026, says the FCA expects to publish a policy statement and make any new rules in Q1 2027. No new rules had been made on 8 October 2026.

The consultation proposed four changes:

• removing business with non-UK customers from the Duty’s scope;
• making it clearer where the Duty applies and where it does not;
• clarifying when and how firms can rely on each other in distribution chains, and how they can apply the Duty more proportionately;
• explaining the interaction between the Duty and other product governance rules.

The four outcomes and the monitoring duty were not among the listed changes. The PRIN 2A sections cited here were last updated on 26 June 2026 (PRIN 2A.4 on 9 December 2025).

Which Consumer Duty evidence can software hold?

Software holds the evidence that is a by-product of daily work: dates, response times, who approved what, and which client fits which service. It does not define good outcomes, write a value assessment or decide on redress; people at the firm do that and sign it off.

Building Filyst, our case management product for immigration firms, showed us why records made at the time are easier to rely on than records rebuilt for a report. Filyst writes an audit log of who did and approved what, and when, and it rejects a stage approval by the person who asked for it. Filyst is not built for advice firms and has no clients yet; the lesson is about how evidence is recorded.

The wider rules for systems and AI in advice firms, including human review of AI drafts, are in Software and AI for UK advice firms under Consumer Duty, the pillar for this topic. Software for financial advisers describes what we build to keep that evidence in connected systems, with a person signing off anything AI drafts.

Frequently asked questions

Sources

1. FCA Handbook PRIN 2.1.1R (the Principles, including Principle 12)
2. FCA Handbook PRIN 2A.1 (application and purpose)
3. FCA Handbook PRIN 2A.2 (cross-cutting obligations)
4. FCA Handbook PRIN 2A.3 (products and services outcome)
5. FCA Handbook PRIN 2A.4 (price and value outcome)
6. FCA Handbook PRIN 2A.5 (consumer understanding outcome)
7. FCA Handbook PRIN 2A.6 (consumer support outcome)
8. FCA Handbook PRIN 2A.7.1R (the prudent firm standard)
9. FCA Handbook PRIN 2A.8 (governance and the governing body report)
10. FCA Handbook PRIN 2A.9 (monitoring of consumer outcomes)
11. FCA Handbook PRIN 3.2.6R to 3.2.11G (Consumer Duty application)
12. FCA, Dear CEO letter: implementing the Consumer Duty for closed products and services, 16 May 2024 (PDF)
13. FCA, Outcomes monitoring: good practice and areas for improvement, 27 July 2026
14. FCA, CP26/23 Consumer Duty: scope and proportionality (page last updated 21 September 2026)