How can Advice Firms Evidence Consumer Duty Outcomes

Consumer duty means what?

Consumer Duty is a regulatory standard. A standard is another word for a flag. Call it a flag if you like. It is designed to raise standards and keep the financial services industry aligned in wanting to improve the underlying consumer experience – over and above the assumed minimum of whether compliance is followed. This is what the FCA said, in February 2026, https://www.fca.org.uk/firms/consumer-duty/about

• Act in good faith towards customers.
• Avoid causing foreseeable harm.
• Enable and support customers to pursue their financial objectives.

But of course, for IFAs and Mortgage Brokers, this means evidence, showing, creating documents to prove to third parties that your work is aligned with Consumer Duty.

For the financial services industry, the pain is having to second guess what is sufficient. For the regulator, as soon as they state exactly what the minimum is set out to be, then firms would game the system to achieve the set minimum, and the initiative would be diluted. So considerable latitude is given to firms to interpret the rules accordingly.

What you need to show

The FCA require all firms to review annually their adherence to Consumer Duty and delivery of good outcomes to clients. Inevitably this leads us to a fill-in-the-blanks template of what sort of document to produce, and our compliance partner IFAC have come up with various templates that are used by hundreds of it’s own IFAs to show compliance with Consumer Duty.

Of course, it is not the template, but the figures and numbers and analysis dropped into the template that proves the compliance with Consumer Duty, and it is the numbers themselves that evidence the Consumer Duty.

The document templates provide an assessment of the outcomes delivered to clients to ensure delivery of good outcomes to all clients. MI is collected and documented to evidence the firm’s delivery of the Consumer Duty and where they can the advisers and advice firms must add in and document their improvements and risk rate them accordingly and then ensure that the firm addresses any gaps.

The report relates to the firm and the work it undertakes.

Characteristics of a Good Report

• Data-Driven: Focuses on concrete evidence rather than just narrative, using qualitative and quantitative metrics.
• Self-Critical: Honest identification of risks, gaps, and areas for improvement, not just highlighting successes.
• Board Challenge: Demonstrates that the Board has actively challenged the findings and reviewed the evidence.
• Clear Structure: Structured to be easily understood by directors and regulators, with a clear focus on customer impact

The report should be completed based on a firm’s own metrics.

This document includes some examples of processes firms may use and data that could be assessed and processed for the regulator.

Firms are encouraged to highlight any actions that come out of the analysis and risk rate them accordingly. This leads to an Action Plan and a cross reference to the Firm’s Risk Register to track progress of any required actions.

If you are still with us, then you’ll realise that the key then is numbers. You need the numbers – and once you’ve got those numbers, you can start to strip out your own Consumer Duty report, and work back to analyse the numbers.

Of course, every director of any firm knows their numbers, - how much is in the bank, how much profit, what the price is, and, in a service industry, be able to reconcile the numbers to an hourly rate, to say, “is this really worth the effort?”

But that’s all well and good, but financial services carries considerable oversight responsibilities, and the numbers, spill into an extraordinary amount of detail, all of which needs to be recorded.

And so, after over 600 words written, I can finally say, “and that’s where BAT comes in!”

BAT is a compliance management system that records all this information for you.

The old wags nod their heads at this point and say things like “Ah, Rubbish in, rubbish out” when referring to data, and busy IFAs are dreading having to input the data, or employ a paraplanner to key in the data as requested.

But now you can sit up and take note that BAT does something that no other firm does quite as easily. It is called DRAG AND DROP.

You simply chuck in the documents, using drag and drop, and BAT will extract the relevant data from the underlying files, and post it accordingly. Now we are talking serious inroads into compliance for the modern IFA firm. Under the reports section in BAT, the data, numbers and metrics required will be readily available, and can be exported into a report.

So here is what exactly the system records, and it is then up to you to put the data into meaningful places. We provide some sort of structure after the data

You need to be able to state all of the below:

• The firm monitor the quality of advice delivered to clients with a file checking process
• The firm monitors KPIs of the firm and its advisers and reviews accordingly
• The firm regular reviews products and platforms we use with clients
• Where a product or service offered by the firm is not being used, we consider why this is (e.g. a model portfolio service portfolio; a product as part of CIP; or an ongoing service level)
• The firm requests feedback from clients in relation to the services provided
• The firm requests feedback from staff on improvements that can be made
• Appropriate information on products which we distribute has been obtained from manufacturers
• The firm has reviewed the target market of its services
• The firm has reviewed its Customer Journey
• The firm has reviewed its advice processes and procedures
• The firm has obtained a third party assessment of its advice processes and procedures
• The firm has read recent FCA Thematic Review/Finalised Guidance on <Insert>
• The firm operates a documented retirement income advice process

How BAT can help

All the above needs to be backed up using MI. BAT strips out the MI from your advice files, and posts it into a structured format for Consumer Duty

Proof/Management Information of how this is being met are all contained inside BAT, and additions can be made using <<manual entry>> where listed below. It is an astonishing list, and effectively puts BAT centre stage under Consumer Duty.

General Stats

• Percentage of files checked per adviser
• Percentage of pre-sale
• Suitable percentage of
• Unclear percentage of
• Unsuitable percentage of
• Percentage of post-sale
• Suitable percentage of
• Unclear percentage of
• Unsuitable percentage of
• Highlight any concerns identified
• Training needs identified
• Remedial action undertaken
• PERCENTAGE OF advisers’ KPIs checked
• Training needs identified
• Highlight any concerns identified (manual entry)

Advice Process

• Panel list
• Products/services not being used
• Highlight any amendments made to the firm’s CIP/Panel (manual entry)

• Outcome of review
• Costs consideration - fair value?
• Insert any changes made/to be made (manual entry)
• Details and evidence that this is being undertaken
• List of products recommended removed from advice process
• Why removed (manual entry)
• Details of feedback received (manual entry)

Business model

• Number of fees charges outside of standard charging structure
• Amount Higher
• Amount Lower
• Provide reasons for deviating from the standard charging (manual entry)
• Number of clients due a review in past 12 months – xx
• Number of clients that were offered a review in the past 12 months – xx
• Number of clients that were offered a review on time - xx
• Number completed – xx
• Number on time
• Number declined - xx
• Number no contact - xx
• Number of ongoing client fees switched off – xx
• Details of action taken when not delivered (manual entry)
• Details of why not concluded within timescales (manual entry)
• Number of clients cancelled
• Refunds given?
• Number of clients moving service levels

Feedback – where BAT used for communication.

• Percentage of clients completing feedback form
• Percentage of initial
• Percentage of ongoing
• Percentage OF engagement

Facts on clients

• Percentage of clients checked
• Number of promotions reviewed – xx
• Number of promotions approved by firm – X
• Number of promotions approved by third party – X
• Meetings held:
• Percentage of Face to Face
• Percentage of Telephone
• Percentage of online
• Detail and feedback received and any changes made (manual entry)

• Number of complaints received in past 12 months – xx
• Number upheld – xx
• Number upheld in part - xx
• Number rejected – xx
• Complaints referred to FOS – xx
• Total redress paid - £xx
• Trends noted and action taken (manual entry)

• Percentage of staff undertaken Training
• Percentage of Annual Testing complete
• Percentage of completed
• Percentage of certificates issues
• Any issues? (manual entry)

• In the past 12 months
• File Reviews undertaken
• 1-2-1 Meeting undertaken
• CPD checks
• Issues encountered and amendments made (manual entry)

• Percentage of Clients with Characteristics of Vulnerability in past 12 months
• Percentage of Clients with no Characteristics of Vulnerability in past 12 months
• Any amendments to service to accommodate clients with characteristics of Vulnerability
• Any additions of tools, assistance etc (manual entry)

That is some list there, and BAT has been designed to help firms deliver this entry. As stated before, the key is that BAT will extract data from documents, PDFs, word documents, text files and excel. This data is extracted and posted and processed for you the user, under the file check system, and it will pre-fill the data entry forms too. Where some manual input will be required is highlighted above, and this is usually made in the commentary word document attached (manually) to the report.