Consumer Duty Board Report: What to Include

Once a year, your firm has to look at whether it is actually delivering good outcomes for its retail customers, write that down, and have it approved at the top. The FCA's rule is that "a firm's board, or equivalent governing body, should review and approve an assessment of whether the firm is delivering good outcomes for its customers which are consistent with the Duty, at least annually."

There is no prescribed format. The FCA is explicit: "Our rules do not set a specific template for the Board report, and it is for individual firms to determine what is appropriate for them."

That freedom is the problem for a small firm. A three-person adviser has no board, no MI team and no template — and still owes an assessment that would stand up if the FCA asked for it. This guide covers what has to be in it, how to produce one without a board, and the expectation that was withdrawn in 2025 and still turns up in guidance written before then.

What the assessment must contain

The FCA sets out four things the assessment should include:

"the results of the monitoring that the firm has undertaken to assess whether products and services are delivering expected outcomes in line with the Duty"
"any evidence of poor outcomes, including whether any group of customers is receiving worse outcomes compared to another group, and an evaluation of the impact and the root cause"
"an overview of the actions taken to address any risks or issues"
"how the firm's future business strategy is consistent with acting to deliver good outcomes under the Duty"

Note what the second one is really asking. It is not "did anything go wrong?" It is a comparative question: is one group of your customers doing worse than another? For a small advice firm the groups worth comparing are usually obvious once you look — clients on legacy charging structures against clients onboarded recently, clients acquired through an introducer against direct clients, or clients with characteristics of vulnerability against the rest of the book. Identifying which clients have characteristics of vulnerability is the input to that last comparison, and the FCA treats vulnerability as a spectrum rather than a category.

And note that a finding of poor outcomes needs root cause, not just description. "Three complaints about charges" is an observation. "Three complaints about charges, all from clients who joined before the 2023 disclosure change, because the older documentation did not itemise the ongoing fee" is an assessment.

What the board has to do before signing it off

Approval is not a rubber stamp. Before signing off, the board or equivalent governing body should agree:

"The action required to address any identified risks."
"Any action required to address poor outcomes experienced by customers."
"Whether any changes to the firm's future business strategy are required."

So the report has to end in decisions, and the decisions have to be recorded as agreed rather than noted. A report that identifies a problem and closes without an owner or a date has not been signed off in the way the guidance describes.

The expectation that was withdrawn — check the date on your guidance

A great deal of Consumer Duty material still tells firms they need a board-level Duty champion. In FG22/5 the FCA did say it expected firms "to have a champion at board (or equivalent governing body) level", ideally an Independent Non-Executive Director.

That expectation has gone. The FCA's current position: "from 27 February 2025 we no longer expect them to have a Duty champion, although they can retain the role should they wish to do so."

The reasoning is that the Duty is now embedded — it came into force for open products and services on 31 July 2023 and for closed products on 31 July 2024 — so the FCA wanted to "provide firms with greater flexibility on their ongoing governance arrangements".

Two practical points. First, if your compliance manual still names a Duty champion as a required role, that is a live example of documentation lagging a rule change, and it is worth checking what else in the manual is the same vintage. Second, dropping the role does not drop the substance: the FCA's rules still "require firms to ensure that their obligations under the Duty are reflected in their strategies, governance, leadership and people policies, including incentives at all levels", and retail customer outcomes must "remain central to the firm's risk control arrangements and internal audit function."

How a firm with no board produces a board report

This is the practical question for most small firms, and unusually the FCA answers it directly: "Smaller firms should think about how they can bring in some independence and objectivity into their assessment in the absence of a Board, for example, through a critical friend who can provide support and challenge."

A "critical friend" is a low-cost, genuinely useful mechanism. In practice it can be a compliance consultant you already use, a non-executive you engage for a couple of hours, or a peer principal at a firm of similar size with a reciprocal arrangement. What it should not be is the person who wrote the report.

The FCA also frames proportionality explicitly: "The length and detail of reports will likely depend on the nature and extent of your firm's business activities and the impact they have on consumer outcomes. The Duty applies in a reasonable way, and we recognise firms will have different capabilities depending on their size, resources and activities."

A defensible small-firm report is a handful of pages. What makes it defensible is not length — it is that the numbers in it are real, the comparison was actually made, and the actions have owners.

What you have to send, and when

Nothing, unless asked. The FCA's position is "You don't need to send us your Board report, but we do expect you to be able to provide it if asked" — and elsewhere, that it expects "to be provided on request with the report and the management information (MI) that sits behind it."

The MI clause is the part small firms underestimate. It is not enough to state a conclusion; you need to be able to produce the underlying data. If your report says complaints were stable, you need the complaints record that shows it. If it says outcomes were consistent across client groups, you need whatever you compared.

On timing: the assessment is due at least annually, and the FCA notes that "for firms with new and existing products and services the first report was due by 31 July 2024." Most firms have therefore anchored their cycle to a July year-end, though the rule is an annual cadence rather than a fixed calendar date.

A workable annual cycle for a small firm

Fix the date and work back. Decide when the assessment is approved, then set the monitoring cut-off six to eight weeks earlier.
Collect the MI you already have. Complaints, file-review outcomes, charging data, client-loss reasons, service turnaround times, vulnerability records. Most small firms have more of this than they think — it is just not gathered in one place.
Run one comparison deliberately. Pick the client split most likely to reveal a difference and look at it properly. One real comparison beats four token ones.
Write the four sections the FCA names, in that order.
Get independent challenge before sign-off — the critical friend.
Record the three decisions with owners and dates.
Feed it back into next year's monitoring, so the actions you agreed are among the things you measure. Our compliance monitoring plan guide covers where this sits in the wider monitoring cycle.

How it connects to the conduct rules

The Duty is not only a firm-level obligation. Individual conduct rule 6 requires those in scope to act to deliver good outcomes for retail customers, so the board report's findings are evidence about how individuals have been performing against a conduct rule — not just about how the firm has performed against a principle.

That matters when the report identifies a poor-outcome pattern attributable to one adviser's practice. The right response is a supervision and competence question rather than an automatic conduct-breach finding, but it should not be invisible to either process. Our Consumer Duty guide sets out the four outcomes and three cross-cutting rules, and our individual conduct rules guide covers rule 6 itself.

Summary

The board or equivalent governing body must review and approve an assessment of whether the firm is delivering good outcomes consistent with the Duty, at least annually.
Four required contents: monitoring results, evidence of poor outcomes including whether one customer group is doing worse than another with impact and root cause, actions taken, and how future strategy is consistent with the Duty.
Before sign-off the governing body must agree the actions on risks, the actions on poor outcomes, and whether strategy needs to change.
There is no template — the FCA leaves format to the firm and applies the Duty proportionately.
The Duty champion expectation was withdrawn from 27 February 2025. Guidance still requiring one predates that change.
A firm with no board should bring in independence another way — the FCA suggests a "critical friend".
You do not send the report in, but you must be able to produce it and the MI behind it on request.

Last reviewed: 20 October 2026. This guide explains the annual Consumer Duty board report for small FCA-regulated firms. It is general information, not regulatory or legal advice, and it does not describe a ConductLog product feature — ConductLog is validating demand for a tool that helps small FCA-regulated firms handle conduct and misconduct processes. Consumer Duty expectations have changed since FG22/5 was published; check the FCA's current Consumer Duty pages alongside the finalised guidance.