Consumer Duty Board Reports in 2025 – What should be in it?

We’re now halfway through 2025 and two years into the Duty, and the pressure to evidence progress is growing. The Financial Conduct Authority has made clear that reporting must go beyond compliance checklists – boards are expected to demonstrate how they have embedded the Duty across the business, assessed outcomes and acted on findings. This presents not just a regulatory obligation but a challenge in shaping clear and structured board reports that meet those expectations without becoming difficult to manage.

Download our Consumer Duty board report template

When the Duty first came into effect, firms were focused on meeting the requirement in PRIN 2A.8.3-5R – the preparation of a report for its governing body on the results of PRIN 2A.9 monitoring. Because the format and content of the report isn’t prescribed - the FCA recognises that what’s covered depends very much on the business and size of each firm – many firms struggled to understand what the construction of the report was meant to look like. These first reports tended to prioritise general evidence that the firm is meeting the Duty. While this sounds right, the Board Report should be showing how the firm is achieving good outcomes for customers.

The FCA’s 2024 review of Board Reports found some areas for improvement around the type of information included in the reports:

• Some firms did not have sufficient data quality to justify conclusions or to give governing bodies adequate assurance that the firm is meeting its obligations under the Duty.

• Some firms don’t include explanations to show how and why the MI is evidence of good outcomes for customers.

• Some reports did not contain evidence that appropriate amount and types of information have been shared between the firm and third parties across the distribution chain.

• Some firms did not evidence that adequate consideration had been given to outcomes for different groups of customers, including those with characteristics of vulnerability.

• It was not always evident that there had been effective challenge from firms’ governing bodies on the content of the reports, for example, through the minutes of board meetings.

• Some action plans and improvements were not accompanied by further details such as timescales, action owners, and clarity on the data that would be used to evidence good outcomes.

This review gives a clear picture around where firms are falling short and offers both a warning and an opportunity for those preparing their 2025 Consumer Duty Board Reports. Board reports should be designed to ensure that firms are both conscious of, and regularly checking in with, how they deliver good consumer outcomes in practice.

Data must be meaningful. If it’s included in the MI, it must evidence an underlying point. The review shows that many firms struggled to present data that genuinely justified their conclusions. In 2025, firms should prioritise data quality over quantity.

MI on its own isn’t enough. The FCA expects firms to explain how and why their data supports their assessment of outcomes – not simply to state that outcomes are “fair” or “reasonable”. Firms should frame their data with interpretation, not assumption.

Reports also need to reflect the whole customer journey, which means firms must ensure they’re sharing and receiving the right information with distributors, partners and third-party providers.

All customers must be considered – not just the average customer. Reports must show how vulnerable customers are identified and supported, and how their outcomes are monitored, distinct from other customers.

Boards must show real challenge and evidence robust debate or scrutiny of the evidence, where appropriate. Board minutes, follow-up actions and decisions taken as a result of Consumer Duty discussions will all contribute to demonstrating governance in practice.

Action plans must assign ownership, set timeframes and define how success will be measured.

The key takeaway here is that the board report shouldn’t be focused on whether the company is compliant with the Duty. Instead, it should demonstrate compliance via a focus on whether customers are getting good outcomes, which in turn, will drive product improvement.

Our range of Consumer Duty template documents help firms to maintain compliance with the requirements of the Duty.

Our Consumer Duty Board Report Template supports effective board oversight through supporting firms to document how their firm is identifying and responding to poor outcomes, and in providing clear board-level commentary and actions.