Same question, different proof: Consumer Duty outcomes monitoring
Week three of Beyond the Hype, a 12-week series from our CEO Charlie Symonds on what modern technology practically means for wealth managers and providers across financial services.
Bloemfontein, June 2010. England are 2-1 down to Germany in the second round of the World Cup when Frank Lampard's shot from the edge of the box beats the keeper, hits the underside of the bar and bounces down a clear yard behind the line. The referee and his assistant, forty yards away with the sun in their eyes, wave play on. Germany win 4-1. [1]
Everyone in the stadium had seen a goal. Within minutes, everyone watching on television had seen it from four angles. The only people whose opinion counted had not, and under the rules as they stood their opinion was the only evidence that mattered. For the best part of a decade FIFA had resisted putting a camera on the line, on the grounds that football should be decided by people. After Bloemfontein that position lasted about a week. [1] [2]
The system that eventually went in was British. Hawk-Eye had been devised in 1999 by Paul Hawkins, an engineer with a doctorate in artificial intelligence, and had spent a decade proving itself in cricket and tennis. The Premier League, which had been testing it since 2006, became the first league in the world to adopt it, from the start of the 2013-14 season: seven cameras per goal, the ball tracked to the millimetre, and a signal to the referee's watch within a second of it crossing the line. [1] [3]
Nothing about the rule changed. A goal has been a goal when the whole ball crosses the line since 1863, and the referee has always had to decide whether it did. What changed in 2013 was the proof. Before Hawk-Eye the evidence was what the officials believed they had seen, delivered from forty yards and argued about for a week. After it, the evidence is a measurement, taken before anyone asks, that the referee, the players and everyone in the ground can see at once.
The FCA is asking firms the question it has always asked. In the last twelve months, the proof it will accept has changed a great deal.
Consumer Duty outcomes monitoring: the question was never new
Advice firms have had to show how a recommendation was reached for as long as there have been suitability rules. Providers have had to treat customers fairly, and evidence it, since long before the Duty. Senior managers have carried personal accountability for it since the Senior Managers regime. [8] Anyone who has sat through a file review knows the question: how did you get to this decision, and can you show me?
What the regulators accepts as an answer has changed in five ways.
The unit of evidence. It used to be the decision, shown through the recommendation, the file and the sign-off. It is now the outcome, for each customer and across the whole book. A well-reasoned suitability report that left the client worse off no longer passes on the strength of the reasoning.
When the evidence exists. Firms have tended to pull evidence together when a file review or visit was due. Outcomes monitoring, fair value assessments and annual board reports now need it kept up to date all year, so it cannot be built after the letter arrives.
What it is compared with. A decision was judged on its own merits. An outcome is judged against thresholds the firm itself defined, across cohorts, including whether customers in vulnerable circumstances fared differently. Answering that needs data on the whole customer population, which a single file cannot provide.
Who sees it. Dashboards and open finance take the record out of the firm and put it in front of the customer and third parties, in a standard format, in real time, so firms have no opportunity to tidy it first.
Where the burden sits. The Duty places the burden on the firm to demonstrate, with its own data, that outcomes are good, and an absence of complaints no longer counts as that evidence.
Taken together, these changes mean the answer now has to come from data, which is why the first two articles in this series looked at joining data up and making it trustworthy.
It is easiest to see from inside a provider. Picture a head of change at a pensions and investments business who is asked a simple question by their board: how many of our customers hold a legacy product where we have a fair value concern, and what are we doing about them? They understand the products and the concern. What they may not have is the answer, because the legacy book sits with a third-party administrator on a different data model, the modern book sits on the in-house platform, and the two have never been asked the same question in the same way. The answer will take six weeks and a reconciliation in a spreadsheet, and it will be out of date by the time it reaches the board paper.
Ten years ago, they would have been asked how the product was approved and whether the file was in order. Today they are being asked what happened to the customers who hold it, and the file does not always contain the answer.
Three pieces of regulation, one standard of proof
Consider what has landed on this market in the last twelve months alone, and notice that none of it asks a new question.
Consumer Duty moved from implementation to evidence
In July the FCA published its review of how firms monitor outcomes under the Duty, and the message was that collecting data and producing management information does not, by itself, show that customers are getting good outcomes. It found frameworks that failed to define what good and poor outcomes look like at each stage of a customer journey, operational metrics such as review completion standing in for outcomes, and little evidence of firms testing whether outcomes differ for customers in vulnerable circumstances. It also found governance that was better documented than demonstrated. [4] That review followed its earlier look at ongoing advice, where 22 of the largest advice firms could show suitability reviews were delivered in around 83% of cases, with clients declining or not engaging in a further 15% and fewer than 2% where no attempt had been made. [5] What mattered more than the number was how firms had to prove it: firms were asked to show, client by client and from their own records, that a service they had always been obliged to deliver had in fact been delivered. The FCA has since proposed, in CP26/10, replacing the mandatory annual suitability review with periodic reviews based on client need, which sounds like relief and is in fact the same shift: fewer prescribed steps, more evidence that the service you chose to deliver was the right one for that client. [11]
Targeted support went live on 6 April
Firms with the new permission can now give suggestions to groups of consumers with common characteristics, which is a halfway house between guidance and advice and potentially reaches 18 million people. [7] It is also, in data terms, a segmentation exercise. You cannot define a group of consumers with common characteristics, make a suggestion to them and monitor whether they ended up in a better position without a record of each customer that you trust enough to put them in the group.
Open finance now has a roadmap
In April the FCA set out its vision for a smart data future, extending open banking principles to pensions, investments, mortgages and insurance by 2030, with a discussion paper on the first scheme due before the end of this year and options for a regulatory framework by the end of 2027. The Data (Use and Access) Act gives the Treasury the powers to create the schemes. The FCA also said that firms which already have data access and the right permissions in place will be supported to bring open finance products to market sooner. [9]
Each of these three initiatives assumes you can produce, join and share customer data on demand. In that sense they work much like the cameras on the goal line: the rule is the one you already knew, and the evidence is now a measurement, taken continuously and visible to people outside the firm.
Set side by side, each one asks for a different kind of proof, and most firms are some way from providing it.
Consumer Duty outcomes monitoring
What it now demands as proof: outcomes defined per journey, measured per customer, tested for vulnerable groups, with evidence the board acted
Where most firms are today: operational MI standing in for outcomes, data held in silos, and board reports better documented than demonstrated
Targeted support
What it now demands as proof: trusted customer attributes to segment on, a record of what was suggested, and monitoring of the group’s position afterwards
Where most firms are today: segmentation built on CRM fields of uncertain quality
Open finance
What it now demands as proof: customer data that can be shared securely, with consent, through standard APIs
Where most firms are today: data that can barely be shared internally
The capability that satisfies all three is the same one: a single, trusted, joined-up record of the customer, with an agreed system of record for each fact, that your people and your systems both use.
If it is useful, you can download this table as a one-page reference.
What I'm seeing
What follows is opinion rather than evidence.
The first thing I see is firms still offering the old proof. Evidence describes the process: the review was scheduled, the letter was sent, the file was checked. That used to be enough, and in many firms, it is still well done. The Duty wants to know what happened to the customer, which can only be shown from the data, and when the two diverge the process file looks complete while the outcome stays invisible.
The second thing I see is that regulation has become the best business case for data that most firms have. A provider that can answer the fair value question in minutes rather than six weeks is also a provider that can price, service and retire products with confidence. An advice firm that can evidence which clients received their review and what changed as a result is also a firm that knows its own cost to serve. Both rely on the same capability, and the regulatory framing is often what secures the budget.
Third, the gap between large and small firms is closing in a way the regulator has noticed. The FCA's July review made a point of saying that smaller firms can use a focused set of indicators, provided they can show how they identify and address harm. [4] That is a proportionate ask, and it is answerable by a 30-adviser firm, but only if the data behind the indicators is trusted.
And finally, the people in the middle of this are tired. Compliance teams have absorbed Consumer Duty, dashboards, targeted support and a consultation on the Duty's scope in the space of three years, usually with the same headcount. Framing each new initiative as a separate compliance project is a large part of why the data never gets fixed, because each project fixes just enough to pass and no more. Treating them as collective demands on one capability is the only version that gets cheaper over time.
Five questions a supervisor might ask
Last week’s exercise tested whether your systems agree with each other, and these questions ask whether they can answer the regulator.
For a given client, what service did they pay for, what did they receive, and where is the evidence?
Which of your customers are in vulnerable circumstances, and do their outcomes differ from everyone else's?
If you offered targeted support tomorrow, which fields would you segment on, and how confident are you in each?
How many customers hold a legacy product with a fair value concern, and how long did that answer take?
If a customer asked for all their data in a form they could share with someone else, could you produce it?
Questions people are asking
What data does the FCA expect wealth and advice firms to evidence under Consumer Duty?
The FCA has not published a list of required data points, deliberately. It expects firms to define what a good and poor outcome looks like at each key stage of each customer journey, to monitor against those definitions with measurable indicators, to test whether outcomes differ for groups including customers in vulnerable circumstances, and to show that the board saw the results and acted. [4] In practice that means a per-customer record of what was promised, what was delivered, what it cost, and what happened next.
What is targeted support and when did it start?
It is a new regulated activity, live since 6 April 2026, that lets authorised firms give suggestions designed for groups of consumers with common characteristics, without the full suitability requirements of personal advice. Firms need a specific FCA permission, must define their consumer segments with care, and remain responsible for monitoring the outcomes of the support they give. [6]
What does the Data (Use and Access) Act mean for financial services?
It gives the Government the power to introduce smart data schemes by sector, which is the legal foundation for open finance. The FCA's roadmap, published in April 2026, sets out how open finance would extend consent-based data sharing to pensions, investments, mortgages and insurance by 2030, with the first scheme to be discussed before the end of 2026 and framework options by the end of 2027. [9] For firms it means customer data will need to be shareable through standard interfaces, with consent, at the customer's request.
Is this really a data problem, or a compliance problem?
Both. The compliance obligation has been in place for years, and the proof the regulator now accepts for it sits in data. Every one of these initiatives can be met with a separate compliance project that fixes just enough data to pass. Or they can be met once, with a single trusted customer record that each of them then draws on. The second route makes each new rule cheaper to meet.
The client's side
A client does not read policy statements. What they notice is whether the firm that charges them an ongoing fee can tell them, without hesitation, what they got for it. Whether the pension they half remember from a job in 2009 turns up on a dashboard. Whether a nudge about their drawdown rate arrived because somebody had actually looked at their situation, or because they fell into a bucket by accident.
Each of the three pieces of regulation above was designed with that person in mind. The regulator is not raising the bar for its own entertainment, but for the proof the client would ask for, if they knew how.
Who's doing it well
The FCA's own review is the best public description of what good looks like, and it is worth reading for that. The strongest firms it saw defined good outcomes in practical terms, by product and by stage of the customer journey, rather than through a single broad statement. They linked each risk of harm to a measurable indicator such as complaints, attrition or compliance monitoring, focused their effort where risk was greatest, and integrated monitoring with governance and remediation so that an issue found in the data led to an action and a check that the action worked. The review also noted innovative use of technology and AI in monitoring. [4]
In its parallel review of products and services, the FCA described firms combining customer feedback, complaints, root-cause analysis and behavioural data into dashboards that surface emerging risks. [10] None of that is exotic. It is a trusted record, joined up, with people who look at it.
What this means for you
If you run an advice firm
The ongoing advice review and the Duty's outcomes focus mean you will be asked, client by client, what was promised and what was delivered. Build the record once and every subsequent question, including the periodic review model proposed in CP26/10, gets easier. Proportionality is real, but it applies to the number of indicators, not to whether the data behind them can be trusted.
If you are a product provider
Dashboards, targeted support and fair value all land on the same customer record, and you probably hold that customer in more than one place. The fair value question for your legacy book is the one to practise on, because it is the one your board is already asking.
If you are a consolidator
Every acquired firm brings its own version of the Duty evidence, its own ongoing advice records and its own gaps. The FCA will treat the group as one firm and ask it one question, so reconciling the customer record across the group belongs inside the Duty programme.
In plain English: Your obligations around customer data
Firms have always had to show how a decision was reached. Under Consumer Duty, a firm must also be able to show, with evidence, that each customer received a good outcome from the products and services they were sold, including fair value for what they paid. That means keeping a record of what was promised, what was delivered, what it cost and what happened next, and being able to produce it for an individual customer or a group. Separately, data protection law gives customers rights over their personal data, pensions dashboards oblige providers to return members’ records on request, and open finance will oblige firms to share customer data securely with third parties the customer chooses. All of these rest on the same thing: a record you trust that you can find, and that you can hand over.
Continue the conversation
Last week Poppy Achilles and Stuart Coleman of Tetmon talked through building a single customer view without a full data platform. If you would like to hear what came out of that session or sign up to the series, you can do so here.
The agenda for the next session, on agentic AI, will be sent out soon. And if any of the five questions above took longer to answer than you expected, I am always happy to have an informal conversation about it, get in touch with the team here.
Goal-line technology left the rule as it was and changed what counts as proof. The FCA has now done the same, and the cameras are already on the line.
Premier League, "The history of goalline technology", 11 April 2013. Lampard's shot crossed the line in the 2010 World Cup round of 16 against Germany; FIFA's position changed afterwards; Hawk-Eye conceived in 1999 by Paul Hawkins; the Premier League worked with Hawk-Eye from 2006 and adopted it from 2013-14. https://premierleague.com/news/60519
WIPO Magazine, "Goal-line technology: getting it right", August 2010, on FIFA's long resistance to goal-line technology and the Lampard decision in Bloemfontein. https://www.wipo.int/web/wipo-magazine/articles/goal-line-technology-getting-it-right-37357
AFP, "Premier League set for goal-line technology", August 2013. First national league to sanction the technology; seven cameras per goal; signal to officials' watches within a second; the system is British-based. https://www.foxnews.com/world/premier-league-set-for-goal-line-technology
FCA, "Outcomes monitoring: good practice and areas for improvement", 27 July 2026, with accompanying summarised blog at Norton Rose Fulbright, by Simon Lovegrove & Charlotte Carnegie, Outcomes monitoring: good practice and areas for improvement | FCA and FCA good and poor practice examples in relation to monitoring consumer outcomes under the Consumer Duty | Global Regulation Tomorrow
FCA, multi-firm review, "Ongoing financial advice services", February 2025. Reviews delivered in around 83% of cases; clients declined or did not respond in a further 15%; fewer than 2% with no effort made. https://www.fca.org.uk/publications/multi-firm-reviews/ongoing-financial-advice-services
FCA, PS25/22, "Supporting consumers' pensions and investment decisions: rules for targeted support". Final rules made 26 February 2026; applications from 2 March 2026; regime live from 6 April 2026. https://www.fca.org.uk/publications/policy-statements/ps25-22-consumer-pensions-investment-decisions-rules-targeted-support
The 18 million figure: FCA press release, December 2025. Millions of people set to get extra help with investments and pensions decisions | FCA
FCA, “Optimising the Senior Managers and Certification Regime”, Policy Statement PS19/20. SM&CR extended to FCA solo-regulated firms from 9 December 2019. Optimising the Senior Managers and Certification Regime: Policy Statement 19/20 and Feedback to CP 19/4 | FCA
FCA, "Open finance: our vision for a smart data future", 14 April 2026. Discussion paper on the first scheme in Q4 2026; framework options with HM Treasury by end 2027; smart data scheme powers under the Data (Use and Access) Act 2025; support for firms that already have data access and permissions in place. https://www.fca.org.uk/publication/corporate/open-finance-roadmap.pdf
FCA, review of products and services under the Consumer Duty, 10 July 2026. Products and services: good practice and areas for improvement | FCA
FCA, CP26/10, "Simplifying the pensions and investment advice rules", June 2026. Proposes replacing the annual suitability review with periodic reviews based on clients' needs and clarifying support for disengaged clients under the Consumer Duty. https://www.fca.org.uk/publications/consultation-papers/cp26-10-simplifying-pensions-investment-advice-rules
