In 2026 the FCA has made one message unmistakable across its Consumer Duty work: it wants evidence, and it has become specific about what doesn't count. When it published the findings of its review into consumer understanding on 13 March 2026, the recurring weakness was firms leaning on sales figures, or the absence of complaints, as proof that customers understood their products. The FCA's view was blunt — that provides no reliable assurance, whatever the size of the firm.
The consumer-understanding review looked across five areas: management information and testing, communications design, vulnerability and accessibility, financial promotions, and governance and oversight. Good practice meant drawing insight from multiple real sources — call listening, complaints, chat transcripts, drop-off data, surveys — testing communications with actual customers before and after changes, and then checking whether the change had worked. Poor practice meant vague, under-embedded processes and ad-hoc fixes with no follow-through. Separately, the FCA's review of second-year Consumer Duty board reports (updated 24 February 2026) noted genuine improvement — better data, clearer action plans, named owners — but flagged that while most boards reviewed and approved their reports, many did not document the challenge they gave. If the minutes don't capture the questions the board asked, it's hard to show that senior leaders tested the evidence at all.
Collecting data and evidencing outcomes are not the same thing.
The direction of travel matters as much as the findings. The FCA is deliberately relying on the Duty rather than writing new prescriptive rules — which makes how well you embed it more important, not less. Two areas are drawing closer attention. Distribution chains are a live focus: firms that reach customers through third parties should expect scrutiny of how they evidence outcomes beyond their own front door. And the FCA continues to sharpen scope — its consultation on Consumer Duty scope and proportionality (CP26/23) was published on 29 June 2026. Meanwhile, the FCA has confirmed it has several active Consumer Duty investigations underway, a number focused on fair value. The regime is being refined, not relaxed.
Why does this catch good firms out? Because collecting data and evidencing outcomes are not the same thing. Sampling two to five percent of interactions, assessing one outcome at a time, or reviewing aggregate MI that hides a poor result for a particular customer group — none of these lets you show that good outcomes are happening consistently, across all four outcomes, for everyone. That gap between "we have MI" and "we can prove outcomes" is exactly where the FCA is now pressing.
What firms should do
- Map the evidence you hold against each of the four outcomes and find where it's thin — usually consumer understanding and support, which often get less attention than products and value.
- Check coverage and granularity: does your monitoring reach the whole customer base or rest on a small sample, and is your MI granular enough to reveal differences by group, product, or channel?
- Test communications with real customers — then close the loop. Confirm the change improved understanding, and act again if it didn't.
- Make board challenge visible. Record the questions asked, the evidence tested, and the follow-up actions in your minutes and papers.
- Look along your distribution chain, not just at your own interactions, and be ready to evidence outcomes there too.
Sources: FCA "Consumer understanding: good practice and areas for improvement" (13 March 2026); FCA "Consumer Duty board reports: good and poor practice" (updated 24 February 2026); FCA CP26/23 Consumer Duty: scope and proportionality (29 June 2026); FCA Enforcement Watch (Jan 2026); Regulation Tomorrow, TLT and Aveni commentary (Feb–April 2026).