Consumer Duty Board Report Template: A Full Annual Outline

TL;DR — Under PRIN 2A.8, every firm subject to the Consumer Duty must produce a board-approved annual assessment that the firm is delivering good outcomes for retail customers. This piece gives you the full outline — four outcome sections, the MI data points the FCA expects, sample metrics, drafting tips, and the named pitfalls from the FCA's December 2024 review.

Table of contents

• What the Duty actually requires of the board
• The FCA's named pitfalls so far
• The full report outline
• Section 1: Executive summary and attestation
• Section 2: Governance, accountability and the Champion
• Section 3: Products and services outcome
• Section 4: Price and value outcome
• Section 5: Consumer understanding outcome
• Section 6: Consumer support outcome
• Section 7: Cross-cutting rules and foreseeable harm
• Section 8: Vulnerable customers
• Section 9: Distribution chain and third parties
• Section 10: Forward-looking actions
• Drafting tips
• FAQ

What the Duty actually requires of the board

PRIN 2A.8.1R requires the governing body of a firm at least annually to:

• Review and approve an assessment of whether the firm is delivering good outcomes for its retail customers, consistent with the Consumer Duty.
• Confirm that the firm's business strategy is consistent with the Duty.
• Agree any action required to address poor outcomes or areas where the firm is not meeting the Duty.
• Agree any action required to address risks to delivering good outcomes.

There is also an obligation to designate a Consumer Duty Champion on the board — a non-executive director (or, in firms without a NED, a senior independent figure) whose role is to challenge management on the Duty.

FS22/5 makes clear the FCA expects the report to be evidence-based, specific and forward-looking, not a re-statement of policies. The regulator has been blunt that boilerplate will not satisfy the rule.

The FCA's named pitfalls so far

In December 2024 the FCA published a review of the first wave of annual board reports it had examined. The pitfalls it called out — and the ones we see most often in client reports — are:

1. No clear conclusion. Boards summarising "areas of focus" without ever stating whether the firm is in fact delivering good outcomes.
2. Lagging MI only. Complaint volumes and Financial Ombudsman referrals are necessary but insufficient. The FCA wants leading indicators — drop-off rates, comprehension scores, switching journeys.
3. No cohort segmentation. Aggregate complaint rates can mask poor outcomes for vulnerable groups, long-tenured customers or particular acquisition channels.
4. Distribution chain ignored. Manufacturers not assessing whether distributors are operating consistently with the target market; distributors not feeding outcomes data back.
5. Foreseeable harm assessed reactively. Harm only identified after a complaint or breach, not via horizon-scanning or scenario analysis.
6. No link to remuneration. Where the Duty has surfaced outcomes issues, firms not articulating how variable pay or scorecards have responded.

A defensible board report addresses each of these explicitly.

The full report outline

The structure below is what we would recommend a Head of Compliance use as a baseline. Adjust depth by line of business.

Section 1: Executive summary and attestation

A one-page summary signed by the Chair and the CEO. It must include:

• A clear conclusion: "The Board has concluded that the firm is / is not / is with the following exceptions delivering good outcomes…"
• The three or four most material findings of the year.
• The actions agreed and the executive owner of each.
• A confirmation that the business strategy remains consistent with the Duty.

Avoid hedged language. The FCA reads this section first.

Section 2: Governance, accountability and the Champion

• Identity and role of the Consumer Duty Champion. Number of meetings attended, number of escalations.
• Committee structure: which committee owns the Duty (most commonly Risk or Customer; sometimes a dedicated Consumer Duty Committee).
• SMF accountability map. Specifically the SMF16 and SMF17 holders' Duty-related prescribed responsibilities.
• Material changes in governance since the prior year.
• How outcomes findings have influenced executive remuneration and scorecards (the FCA expects to see linkage).

Section 3: Products and services outcome

For each material product:

• Target market statement — who the product is designed for, refreshed in the reporting year.
• Distribution strategy — how the product is sold, to whom, and whether actuals match plan.
• Outcomes data:
• First-payment-missed rates (credit)
• Persistency rates (insurance, savings)
• Withdrawal patterns (investment)
• Switching out within X months of onboarding
• Manufacturer / distributor reviews carried out, dated, with conclusions.
• Foreseeable harm review — what scenarios were assessed, what mitigants were put in place.

Sample metric: "In the year, 4.2% of customers acquired through Channel A missed their first payment, versus a portfolio average of 1.1%. Channel A was paused on 14 November and an enhanced affordability check introduced before re-opening."

Section 4: Price and value outcome

• The firm's fair value methodology and any change during the year. A primer on methodology is in our Consumer Duty fair value assessment guide.
• For each product, a fair value matrix:
• Total cost of ownership (headline rate plus all fees and charges)
• Benefits delivered
• Cohort segmentation (new vs renewal; vulnerable vs not; tenure bands)
• Benchmark used and source
• Conclusion (fair / fair with conditions / not fair) and action
• Loyalty premium / price walking analysis (general insurance, savings).
• Where fees vary by customer (e.g., risk-based pricing), the rationale and the outcomes monitoring.

Sample metric: "Customers in the lowest decile of engagement (one or fewer logins per year) on the legacy easy-access savings product received an average rate of 0.85%, against a market top-quartile of 4.10%. A migration campaign was launched in March; 62% of affected customers have moved or been contacted with a like-for-like offer."

Section 5: Consumer understanding outcome

• Inventory of customer communications by channel (marketing, sales, in-product, post-sale, collections).
• Comprehension testing methodology and results. State the comprehension threshold the firm uses and how many communications fell below it.
• Volume and outcomes of marketing communications review — number of pieces approved, number rejected, top reasons for rejection.
• For digital journeys: drop-off and dwell-time analytics at points of material disclosure.
• Vulnerable customer accessibility — large print, audio, plain English, alternative formats.

Sample metric: "12,400 pieces of customer communication were reviewed by Compliance in the period. 7.8% were amended before release; the top three reasons were unsupported performance claims, ambiguous fee language and missing risk warnings."

For practical examples of where each outcome typically bites in real customer interactions, see our companion piece on Consumer Duty examples in practice.

Section 6: Consumer support outcome

• Service-level performance: time-to-answer, time-to-resolve, abandonment rates — across channels and segmented by complexity.
• "Sludge" testing — time and effort required to perform the four core journeys (open, switch product, complain, close).
• Complaints data: volume, root cause, Financial Ombudsman referral rate, FOS upheld rate.
• Vulnerable customer support — specialist team coverage, training completion, outcomes.
• Operational resilience incidents that materially affected customer support and the remediation.

Section 7: Cross-cutting rules and foreseeable harm

• The firm's foreseeable harm horizon-scan process. Who runs it, how often, what scenarios were examined this year.
• Specific harms identified and the mitigants.
• New product approval committee output — any product rejected on Duty grounds.
• AI / model risk lens — where the firm uses models in pricing, collections or affordability, how those have been reviewed for foreseeable harm.

Section 8: Vulnerable customers

• Definition of vulnerability used by the firm (aligned to FG21/1's four drivers).
• Proportion of customer base identified as having a vulnerability characteristic.
• Outcomes comparison: are vulnerable customers experiencing equivalent outcomes to non-vulnerable? If not, what is the gap and what is being done.
• Training coverage and refresher schedule.

Section 9: Distribution chain and third parties

Particularly important for manufacturers and platforms.

• List of material distributors and the outcomes feedback the firm receives from each.
• Material issues identified in the year and remediation.
• ARs and IARs — how the firm supervises them on the Duty.

For firms subject to overlapping financial promotions rules, the same evidence often serves both regimes. We unpack the 2026 state of play in financial promotions rules 2026.

Section 10: Forward-looking actions

The FCA wants to see the report concludes in commitments, not just a backward look. Each action should have:

• Description
• Outcome it is intended to deliver
• Owner (named SMF)
• Deadline
• Metric by which success will be measured

Drafting tips

• Lead with conclusions, not process. The reader should know by paragraph two whether the firm is delivering the Duty.
• Quantify everything. "Materially improved" is not evidence. "Reduced abandonment rate from 18% to 11%" is.
• Show cohort splits. One aggregate number, then the cohort splits underneath. Vulnerable, channel, tenure, product version.
• Name accountable executives. The FCA will use the report as a map for who to call in for interview under section 166.
• Don't bury bad news. Boards that surface issues with a clear plan fare materially better in supervisory engagement than boards that bury them and have to disclose them later.
• Reuse the same MI through the year. If the metric only appears in the board report, the FCA will ask why it was not on a management dashboard.

FAQ

Is the Consumer Duty board report mandatory? Yes, under PRIN 2A.8.1R, for any firm in scope of the Duty. The board must approve it at least annually.

Does the report need to be filed with the FCA? No. It is held internally and produced on request, including in a section 166 or supervisory engagement.

What is the deadline? The first report was due by 31 July 2024 for open products. Subsequent reports are due annually thereafter, on a date set by the board. Most firms align with the financial year end plus six months.

Who signs the report? There is no prescribed signatory, but practice has settled on the Chair signing on behalf of the board, with the CEO and SMF16 named.

How long should it be? We see well-run reports between 40 and 120 pages including appendices. Length is not the test; evidentiary density is.

Does the Consumer Duty Champion draft the report? No. The Champion challenges the report. Drafting is typically led by the Head of Compliance, with input from Risk, Customer, Operations and Marketing.

What is the relationship to the SMCR statement of responsibilities? The Duty does not change SoRs but it adds substantively to what the SMF16 and the Consumer Duty Champion will be asked about. Update SoRs to reflect Duty accountability explicitly.

Benchmark your firm's enforcement exposure

The board report is one half of the picture. The other half is asking what enforcement risk your firm is carrying right now. Sedric's free Enforcement Risk Scorecard is a 12-question diagnostic — covering Consumer Duty, financial promotions, fair value and vulnerable customer outcomes — that returns a written risk profile within 24 hours, modelled on the patterns the FCA has called out in recent thematic reviews. Take the Enforcement Risk Scorecard.