The FCA’s recent good and poor practice review of Consumer Duty board reports is clear on one point: narrative without evidence is no longer sufficient. Boards are expected to demonstrate, with structured and reliable data, how they are monitoring outcomes, identifying risk and acting where standards fall short.
Alongside this, the Consumer Duty Data Forum’s guide, How to Manage and Report Your Data reinforces the same message. Data is not a by-product of systems; it is a core governance asset. The common thread between the FCA’s findings and the Data Forum’s framework is that firms need to improve how they identify, access, monitor and report data across the advice lifecycle.
What the FCA is seeing in board reports
The FCA highlights a divide between firms that treat Consumer Duty reporting as a compliance exercise and those that use it as a management tool.
Stronger reports tend to:
- Clearly link MI to the four Consumer Duty outcomes.
- Include quantitative evidence, trend analysis and segmentation.
- Show challenge from the board and documented actions taken.
- Explain methodologies for value assessments, vulnerability identification and service delivery monitoring.
Weaker reports, by contrast:
- Rely heavily on high-level narrative with limited data.
- Present isolated metrics without context, trends or thresholds.
- Fail to evidence how foreseeable harm is identified or mitigated.
- Do not clearly demonstrate board challenge or decision-making.
The regulator’s direction of travel is consistent with its broader data-led supervision strategy. Section 165 requests, adviser surveys and the Transforming Data Collection programme all point to more structured, comparable and reusable data. Firms that cannot evidence data lineage, definitions and controls will struggle under scrutiny.
Data skills: a board responsibility
One of the most practical sections of the Data Forum guide focuses on improving data skills . It emphasises baseline data literacy across roles and the need for a common glossary of key terms such as client, product, charges, suitability and vulnerability.
This is not a technical issue. It is a governance issue. If the board does not understand what sits behind a metric, how it is calculated or where it originates, it cannot provide effective challenge. The FCA’s findings on weak reports often reflect this gap.
Firms should be able to:
- Compare datasets across CRM, platform and finance systems to identify breaks.
- Monitor completeness and timeliness of reviews and servicing.
- Segment clients consistently by life stage, servicing tier, product mix and review frequency.
Board reporting should show not only what the data says, but how confident the firm is in the integrity of that data.
Assessment and access: knowing your source of truth
The guide stresses clear system ownership and defining a “source of truth” for core data fields such as client status, fees and review dates . Unmanaged spreadsheets and duplicated records undermine the credibility of any Consumer Duty report.
From a board perspective, this translates into three questions:
- Where is the data stored?
- Who owns it?
- How is access controlled?
Access controls, least-privilege principles and documented data flows are not peripheral IT concerns. They are central to ensuring that board MI is accurate, protected and reproducible. The same applies to distribution chain data flows under PRIN 2A.3.16–18, where firms must evidence how they gather and share information with product providers.
If a board report states that target markets are being met or that fair value is evidenced, the underlying data trail must support that conclusion.
Monitoring: trend analysis over snapshots
The FCA expects firms to move beyond static snapshots. Good practice includes trend analysis, exception reporting and thresholds for escalation.
The Data Forum guide highlights the importance of formalised data storage through data lakes and data warehouses . Clean, structured data underpins dashboards, MI packs and Consumer Duty monitoring. Without this structure, trend analysis becomes manual and error-prone.
Effective monitoring should cover:
- Foreseeable harm indicators.
- Vulnerability trends and service adjustments.
- Cost and value assessments over time.
- Complaints root cause analysis linked to product or adviser segments.
Boards should see RAG-rated metrics with defined tolerances and documented management actions. The absence of thresholds or trigger points is a recurring weakness identified by the FCA.
Reporting: structure, explainability and AI oversight
The FCA’s review also intersects with the safe and ethical use of AI. The Data Forum guide is clear that AI outputs must be explainable, governed and subject to human oversight . If AI tools are used to generate MI, monitor files or segment clients, boards must understand:
- What tools are in use.
- What data they access.
- How outputs are validated.
- How bias and inaccuracies are monitored.
Consumer Duty reporting must show how technology supports good outcomes, not just efficiency.
Structured reporting aligned to FCA definitions, prepared for potential Section 165 requests , and mapped against returns schedules, is increasingly part of business as usual. Treating data as a core asset, as the guide sets out, is no longer optional.
The role of RegTech: automated, CRM-integrated board reporting
For many advice firms, the challenge is operational rather than conceptual. The FCA is asking for consistent, granular and trend-based data, but much of that data sits fragmented across CRM systems, platforms and spreadsheets.
Model Office RegTech addresses this by:
- Integrating directly with core CRM systems to extract structured data on clients, reviews, fees, vulnerabilities and outcomes.
- Automating Consumer Duty dashboards aligned to the four outcomes.
- Applying defined data standards and reconciliation checks to improve integrity.
- Producing board-ready reports with trend analysis, RAG ratings and documented action tracking.
- Maintaining audit trails to support Section 165 requests and supervisory engagement.
The value is not simply automation. It is consistency, traceability and governance. Boards receive evidence-based reporting grounded in defined data fields rather than manually compiled narrative.
The FCA’s message is consistent: Consumer Duty board reports must demonstrate identification, access, monitoring and reporting of data in a structured and controlled way. Firms that invest in data skills, system ownership, integrity controls and automated reporting frameworks will be better placed to evidence good outcomes. Those that rely on fragmented MI and retrospective explanation will find supervisory engagement more challenging.
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