What happened?
The FCA published findings from its review of firms’ outcomes monitoring arrangements, highlighting examples of good practice and areas for improvement. While many firms have invested significantly in Consumer Duty frameworks, dashboards and MI, the regulator found that some continue to focus on reporting activity rather than evidencing outcomes.
The review emphasises the importance of defining what good customer outcomes look like, monitoring outcomes across customer journeys, assessing outcomes for vulnerable customers and demonstrating how governance processes lead to meaningful action and improved outcomes.
Why does it matter?
The FCA expects firms to move beyond collecting data and producing reports. Firms need to show how monitoring identifies potential harm, what actions have been taken in response and whether those actions have improved customer outcomes.
As regulatory scrutiny of Consumer Duty continues, firms that cannot evidence this connection between insight, intervention and outcome may struggle to demonstrate the effectiveness of their Consumer Duty framework.
Who is affected?
- Wealth and asset managers
- Banks and building societies
- Insurers
- Consumer finance firms
- Mortgage and lending providers
- Financial advisers and intermediaries
- Board members and senior managers
- Consumer Duty, compliance, risk and governance teams
Key risks
- Management information measures activity rather than customer outcomes.
- Firms cannot clearly define what a good customer outcome looks like.
- Customer journey monitoring fails to identify emerging risks and foreseeable harm.
- Vulnerable customer outcomes are not adequately assessed or evidenced.
- Governance forums review information but cannot demonstrate action or improvement.
- Firms are unable to evidence the effectiveness of interventions during FCA scrutiny.
Actions to take
- Define clear and measurable customer outcome expectations across key customer journeys.
- Review existing MI to ensure metrics are linked directly to customer outcomes.
- Test whether monitoring identifies emerging customer risks and foreseeable harm.
- Embed vulnerability monitoring throughout the customer journey.
- Strengthen governance processes to evidence challenge, decision-making and intervention.
- Establish clear evidence trails linking insights, actions and improved outcomes.
Wider implications
The FCA’s findings signal a continued shift from framework implementation to evidencing effectiveness. Firms are increasingly expected to demonstrate not only that monitoring processes exist but that they deliver tangible benefits for customers.
The review also reflects greater regulatory focus on vulnerability, customer journey analysis and governance accountability. Firms that can evidence outcomes effectively are likely to be better positioned for future Consumer Duty reviews and supervisory engagement.
Recommendations
TCC Group supports firms in assessing, challenging and enhancing their Consumer Duty frameworks to ensure outcomes monitoring goes beyond reporting and delivers meaningful evidence of good customer outcomes.
Our experts are supporting firms with:
- independent reviews
- outcomes testing
- file assessments
- governance assurance
- customer journey analysis
- identifying potential gaps in compliance frameworks
- building stronger evidence for FCA scrutiny
- assessing how AI and technology can strengthen outcomes monitoring and emerging risk identification
Supporting sources
Frequently asked questions
What does the FCA expect from outcomes monitoring under Consumer Duty?
The FCA expects firms to do more than collect data and report MI. Firms should be able to explain how monitoring identifies customer risks, what actions have been taken in response and whether those actions have improved customer outcomes.
Why are customer journeys important for outcomes monitoring?
Monitoring outcomes across customer journeys helps firms identify where customers may experience friction, confusion, delays or potential harm. This provides a more complete view of customer outcomes than relying solely on high-level performance metrics.
How should firms assess outcomes for vulnerable customers?
Firms should be able to demonstrate whether customers in vulnerable circumstances experience different outcomes to the wider customer base. Where differences exist, firms should understand the causes, assess potential harm and implement appropriate improvements.
What are boards and senior leaders expected to demonstrate?
Boards and senior leaders should be able to show that governance challenge leads to action and that actions are monitored through to improved customer outcomes. Oversight alone is unlikely to be sufficient.
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- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Motor FinanceTCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny.
- Payments & FinTechTCC helps payment institutions, e-money firms, FinTechs, challenger businesses and regulated technology providers strengthen compliance, manage regulatory change and demonstrate effective customer outcomes. From financial crime controls and APP fraud prevention to operational resilience, safeguarding and Consumer Duty governance, we help firms build regulator-ready frameworks that support growth without compromising control. For more than 25 years, TCC has helped FCA-regulated firms navigate evolving regulatory expectations with confidence.