Consumer Duty Evidence: What Counts, What Does Not, and How UK Firms Track It

Consumer Duty came into force on 31 July 2023 for new and existing products and services. Since 31 July 2024, the Duty extends to closed products and services. The FCA expects firms to deliver good outcomes for retail customers across four areas: products and services, price and value, consumer understanding, and consumer support.

For UK wealth management and financial advice firms, Consumer Duty creates a new standard for evidence. Saying you deliver good outcomes is not enough. The FCA expects firms to demonstrate, with data and documentation, how their advice process produces good outcomes for each client.

What the FCA means by "evidence"

The FCA's guidance (FG22/5) sets out three layers of evidence firms need to maintain.

At the firm level, firms need MI (management information) showing aggregate outcomes across their client base. What proportion of clients are in products appropriate for their risk profile? What is the distribution of charges across different client segments? Are vulnerable clients receiving appropriate support?

At the product level, firms need to show their product governance process. For each product on the firm's panel or centralised investment proposition, there should be a target market assessment, a value assessment, and evidence of regular review.

At the individual client level, each advice file needs to demonstrate the four outcomes are met for this specific client. The suitability report is the primary vehicle for this evidence, but supporting documentation matters too: the fact find, meeting notes, risk assessment results, charges comparisons, and any vulnerability assessments.

How firms track Consumer Duty evidence today

The benchmark data and discovery conversations with UK advice firms paint a consistent picture. Most firms track Consumer Duty evidence through a combination of spreadsheets, shared drives, and manual processes.

A common approach: the compliance team maintains a spreadsheet listing each advised client, the date of last review, the outcome of the most recent file check, and any remedial actions required. The spreadsheet links (or more often, does not link) to the underlying documents in SharePoint, the CRM, or a document management system.

The problem with this approach is twofold. First, the spreadsheet is disconnected from the source evidence. If a compliance officer needs to verify a specific claim, they still need to find the relevant document, locate the right page, and confirm the data matches. Second, spreadsheets do not scale. A firm with 500 active clients and 10 advisers generates thousands of data points per year. Managing this in a spreadsheet is fragile and time-consuming.

The four outcomes in practice

Products and services: The firm needs to evidence its product selection process. Why is this platform on the panel? Why this DFM service? How does the firm's centralised investment proposition match the needs of different client segments? For each client, the suitability report should explain why the recommended product is appropriate for their specific circumstances. Price and value: The firm needs to demonstrate the client receives fair value for the charges they pay. This means comparing charges against alternatives and explaining the rationale for the chosen option. If the firm recommends an actively managed fund at 0.75% over a passive alternative at 0.15%, the report should explain why the higher charge is justified for this client. Consumer understanding: Communications with the client should be clear, fair, and not misleading. Meeting notes, client letters, and suitability reports should use language the client understands. If the client has lower financial literacy (a vulnerability indicator), the firm should adapt its communication style. Consumer support: The firm needs to evidence ongoing support. How does the firm handle client queries? What is the process for annual reviews? How are changes in client circumstances captured and acted on?

Where the evidence gaps appear

Three common gaps show up in Consumer Duty compliance reviews.

First, the value assessment gap. Firms have a process for assessing value at the product level, but the link between the product-level assessment and the individual client recommendation is weak. The suitability report says "we recommend Platform X," but the file does not show a comparison of Platform X against Platforms Y and Z for this client's specific holding size and product mix.

Second, the vulnerability gap. The FCA's vulnerability guidance (FG21/1) identifies four drivers of vulnerability: health, life events, resilience, and capability. Many firms record vulnerability at the point of initial advice but do not revisit the assessment at annual review. The evidence of ongoing monitoring is thin.

Third, the traceability gap. When a compliance officer reviews a file, they need to connect the recommendation in the suitability report to the evidence in the fact find, the risk assessment result, the charges comparison, and the client's stated objectives from the meeting. If these documents sit in different systems with no linking, the file check becomes an exercise in detective work.

Building evidence into the workflow

Firms with the strongest Consumer Duty evidence share one characteristic: evidence is a byproduct of the advice process, not a separate activity. When a paraplanner completes a fact find and the data automatically links to the suitability report, evidence is created at the point of work. When every extracted field carries a citation back to the source document, page, and paragraph, the audit trail builds itself.

The alternative, which is how most firms operate today, is evidence by reconstruction: going back after the advice is delivered and assembling proof from scattered sources. This is slow, error-prone, and creates the compliance gaps the FCA most often identifies.