The Consumer Duty board report: what the FCA says good looks like

Most advice firms are confident they act in their clients' interests. Proving it in a board report, with evidence a board can challenge, is a different job.

Three years ago this month, the Consumer Duty came into force. The anniversary matters for a practical reason: board reports are annual, and the FCA has now reviewed how firms handled their first ones. It published examples of good practice and areas for improvement, and in February 2026 it added extra insight for smaller firms.

If your Consumer Duty board report is landing about now, that review is the closest thing you'll get to marking guidance.

What the FCA reviewed

The regulator looked at firms' first annual reports and grouped its findings into four areas: report governance, monitoring and outcomes, actions taken to comply with the Duty, and future business strategy.

It was careful to say the examples aren't prescriptive. There's no mandated template, and the FCA isn't asking every firm to produce the same document. The question underneath all four areas is simpler: can your board see what's happening to customers, challenge it, and show that it acted?

What good looked like

Two things stood out in the stronger reports.

They started from customer outcomes rather than activity. Not "we sent 400 annual review letters" but "here's what clients actually experienced this year, and here's where it wasn't good enough."

And they let the data speak, even when it was uncomfortable. A report that only contains good news isn't evidence of oversight, it's evidence of filtering.

Worth noting: the FCA found good practice in firms of all sizes, including teams of fewer than ten people. Size wasn't the differentiator. Evidence was.

Where reports fell short

The weaker reports shared a pattern. Data quality too thin to justify the conclusions being drawn. MI handed to the board with no explanation of what it showed or why it mattered.

A pack of charts is not assurance. If the board can't interrogate the numbers, it can't evidence oversight, and the report becomes a formality rather than a tool.

What this means for the firms we build for

In our experience, weak evidence is rarely a diligence problem. It's a systems problem.

The information usually exists: first enquiries, advice given, reviews completed, complaints, vulnerability flags. But it sits scattered across a CRM, some spreadsheets and a lot of inboxes. Assembling it into something a board can actually challenge burns days of someone's year, which is exactly why it so often arrives thin.

That gap is a big part of why we built Glimzer, a CRM and practice management platform for UK financial advice firms that keeps first enquiries, pipeline, new business and ongoing client servicing in one place. When the underlying records live together, the outcomes evidence your board needs becomes a report, not a project.

To be clear about the boundary: no software writes your board report for you, and none should claim to. The judgement stays with you and your board. Good systems just mean the data behind that judgement is already in one place, and already explained.

What's next

The Duty itself is still moving. On 29 June the FCA opened CP26/23, a consultation on the scope and proportionality of the Consumer Duty. Whatever comes out of it, the direction of the last three years hasn't changed: boards are expected to know what their customers experience, and to show their workings.

If you run an advice firm and you've ever wondered whether there's a better way to manage your pipeline and your ongoing client work, we're always happy to show you around. You can see Glimzer for yourself at glimzer.com.