Consumer Duty after implementation: how wealth firms can evidence outcomes at scale

Why Consumer Duty now demands scalable, evidence-based customer outcome monitoring

The UK’s Consumer Duty regime has moved well beyond a box-ticking exercise. With the Duty now firmly past its initial implementation deadline, the Financial Conduct Authority (FCA) is increasingly focused on whether firms can evidence, monitor and explain the outcomes customers are actually receiving.

For mid-sized wealth and retirement firms, this represents a structural challenge rather than a compliance task. Embedding outcome evidence into everyday decision-making is no longer optional but is fast becoming a source of regulatory resilience and competitive advantage.

In its September update, the FCA signalled that its priorities through 2026 will focus on embedding the Consumer Duty across sectors and improving consumer outcomes in practice. Central to this is firms’ ability to collect, interpret and act on data that demonstrates whether good outcomes are being delivered.

This expectation is reinforced in the FCA’s recent supervisory work. In a dedicated review of insurance firms, the regulator stated that firms must “regularly assess, test, understand and evidence the outcomes their customers are receiving under the Consumer Duty.”

The message is clear: supervisory attention has shifted away from process documentation and towards evidence and insight. The FCA’s non-Handbook guidance further confirms that outcome monitoring should be integrated into risk management, governance and product oversight frameworks rather than treated as a parallel reporting exercise.

The operational reality for mid-market firms

Many mid-sized wealth and retirement firms now find themselves caught between rising regulatory expectations and the technical limitations of their existing tools. Legacy modelling environments, spreadsheet-based projections and manual data management processes were never designed to support repeatable, outcome-focused evidence at scale.

The FCA’s recent multi-firm reviews suggest this is not an isolated issue. Even among larger firms, monitoring frameworks often rely too heavily on process completion metrics rather than interpretable outcome data that can support meaningful challenge by boards or supervisors.

At the same time, commercial constraints frequently rule out wholesale platform replacements. Firms that depend on siloed actuarial tools or static adviser workflows lack the flexibility required to demonstrate defensible outcomes across products, channels and customer cohorts.

Rethinking Consumer Duty as a capability, not a project

Leading firms are now reframing Consumer Duty as a repeatable, data-driven operational capability, rather than a regulatory initiative with a fixed end-date.

This means strengthening assumptions governance, applying consistent decision logic across channels and ensuring that outcomes can be explained in ways that are robust, traceable and regulator-ready. Industry commentary, including Deloitte’s analysis, highlights that successful embedding will depend far more on how firms manage and use data and analytics than on manual MI processes.

Crucially, meeting these expectations does not require multi-year platform transformations. A more targeted and sustainable approach is to centralise outcome modelling in a shared analytical layer that feeds multiple tools and journeys.

The role of an analytics fabric

An analytics fabric is not a single system or reporting layer. Instead, it represents a shared analytical foundation that governs how assumptions, scenarios and outcome logic are defined, reused and evolved over time.

By establishing reusable modelling capabilities above core platforms, firms can apply consistent assumptions and decision rules across adviser-led interactions, digital journeys and operational processes. This ensures that every channel draws on the same underlying logic, rather than recreating calculations in isolation.

This matters because the Consumer Duty does not assess outcomes in silos. Boards and supervisors increasingly expect firms to demonstrate that outcomes are consistent, explainable and repeatable, regardless of how a customer interacts with the business.

Fragmented tools and duplicated logic make this extremely difficult to evidence. The challenge is particularly visible in orphaned client scenarios, where adviser relationships end due to retirement, consolidation or business change. In these cases, firms remain fully responsible for ensuring customers continue to receive good outcomes.

Without consistent modelling and monitoring logic, outcome evidence cannot rely on adviser judgement or bespoke tooling. A modular analytics fabric allows firms to test outcomes across cohorts, rerun scenarios as assumptions evolve and trace how decisions were formed, without rebuilding core infrastructure.

From reporting to reusable decision logic

In practical terms, this approach shifts key Consumer Duty activities, such as outcome testing, value assessments, scenario analysis and cohort monitoring, out of ad-hoc reporting and into a shared analytical capability.

Rather than recreating assumptions separately for adviser tools, digital journeys and board MI, firms define them once and reuse them consistently. Changes to assumptions or regulatory interpretation are applied centrally and reflected across customer-facing tools and internal reporting at the same time.

This significantly shortens the time between regulatory insight and operational change, enabling firms to adapt in weeks rather than years. Scale is achieved not by expanding teams or recalibrating platforms, but by reusing unified decision-making logic.

The next chapter

The Consumer Duty has entered a new phase, where the quality of evidence and the consistency of insight matter far more than checklists, policies and tick-box controls.

Firms that build the capability to measure, test and explain customer outcomes will be better positioned for regulatory engagement, board oversight and long-term trust. For mid-sized wealth and retirement firms, success does not require replacing core platforms, but it does demand defensible outcome infrastructure built on strong analytics, governance and automation.

For those that get this right, Consumer Duty becomes less of a compliance burden and more a catalyst for smarter decisions and better consumer outcomes.