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July 22, 2025
Elly Miller, Technical Consultant at ICS, outlines how firms can get top marks for Consumer Duty board reports.
The Financial Conduct Authority's recent thematic review of 180 board reports has highlighted crucial insights that demand immediate attention from financial services professionals. As we are in the midst of the 2025 reporting cycle, directors must reimagine their approach to Consumer Duty compliance.
Key Findings: What the FCA revealed
The review highlighted five critical areas where firms are falling short:
- Insufficient data quality - Many organisations lack robust data to substantiate their consumer outcomes. Boards must demand more rigorous metrics that genuinely demonstrate customer experience,
- Vulnerable customer oversight - A significant blind spot emerged in how firms track and support vulnerable customers. Comprehensive analysis of different customer groups is no longer optional.
- Weak board challenge - Many reports showed minimal evidence of meaningful board scrutiny. Directors must actively interrogate the compliance narrative.
- Incomplete action planning - Action plans frequently lacked specificity: missing clear timelines, ownership, and measurable success criteria.
- Cultural disconnection - Reports often failed to demonstrate how consumer duty principles are truly embedded in organisational culture.
Action items for directors
However, there are some effective, immediate steps directors can take to improve their reporting going forward. ICS would encourage all stakeholders to relook at their reports in the light of the FCA’s findings from its thematic review.
These key steps include:
- Conducting a comprehensive review of your current consumer duty monitoring processes
- Developing granular metrics that track customer outcomes across all segments
- Creating a dedicated vulnerable customer assessment framework
- Establishing clear accountability for consumer duty implementation
Furthermore, reports should include detailed outcome-focused sections, quantitative and qualitative data, and clear evidence of board challenge.
Additionally, reports should specify time-bound action plans and include explicit cultural commitment statements.
To ensure reporting requirements are being met, directors must embed Consumer Duty into strategy and view it as a dynamic, evolving commitment and integrate customer perspective into board-level discussions.
The key to success is to treat reporting as a continuous improvement process, not a compliance checkbox. Successful implementation of Consumer Duty goes beyond reporting. It requires a fundamental shift in organisational mindset, prioritising customer outcomes at every strategic decision point.
Directors who approach consumer duty as a strategic opportunity rather than a regulatory burden will differentiate themselves in an increasingly customer-centric financial landscape.
The 2025 Consumer Duty board report is your firm's opportunity to demonstrate genuine commitment to customer welfare. Approach it with transparency, rigour, and a genuine desire to drive meaningful change. And if you need support dotting the Is and crossing the Ts, ICS is here to help!
If you would like information about how Insurance Compliance Services can help by providing you with Consumer Duty Guidance, please call us and talk to one of our Consumer Duty consultants on 01892 539600 or email us at:
Find out more about the Consumer Duty and the Board Report (including a Consumer Duty board report template request) using the links below.
