The Duty is no longer an implementation project. It is the lens through which the FCA supervises, and the question has moved from "have you done it" to "can you prove it worked". That is an evidence problem, and evidence about customer outcomes is fundamentally a behavioural question: what customers understood, what they chose, and what happened to them as a result.

Outcomes monitoring and board reporting

Designing the data that tells you whether customers are actually getting good outcomes, and turning it into board MI a non-executive can interrogate. Most firms have volumes of process metrics and very little outcome evidence.

Annual board report support

Independent challenge on your annual Consumer Duty board report before it goes to the board, or help building it from the ground up. This is the document a supervisor will ask for first.

Fair value assessments

Reviewing price and value assessments for defensibility, and building an approach that holds up under scrutiny rather than one that concludes every product is fairly priced.

Consumer understanding and communications testing

Applying a behavioural lens to whether your customers actually understand what you have told them. Comprehension is testable, and testing it is more persuasive to a supervisor than asserting it.

Distribution chain reviews

Assessing how the Duty flows through your distribution arrangements and where accountability sits when a product reaches a customer through several hands. An area the FCA has been actively clarifying.

Vulnerability frameworks

Practical vulnerable customer approaches that front-line staff can actually apply, and evidence that they do.

Consumer Duty health check

A short, fixed-scope diagnostic that tells you where you are exposed and what to fix first. A useful starting point where the answer to "how are we doing on the Duty" is a shrug.