The Consumer Duty Board Report was meant to be a moment of honest reflection. For too many firms, it has become a compliance exercise. Here is what the FCA actually wants to see. perience has not changed?
Every firm subject to Consumer Duty is expected to produce an annual board report reviewing the outcomes their customers are receiving. For firms with vulnerable customers in their base, and that is most firms, the report needs to demonstrate more than activity. It needs to show impact.
We have reviewed Consumer Duty Board Reports across financial services and the pattern is remarkably consistent. Firms describe what they have done. Training delivered. Policies updated. Identification rates reported. But very few answer the question the FCA is actually asking: are your vulnerable customers getting good outcomes?
What the FCA expects
FG21/1 set out clear expectations for the treatment of vulnerable customers in financial services. Consumer Duty raised the bar further by requiring firms to evidence that they are delivering good customer outcomes across four areas: products and services, price and value, consumer understanding, and consumer support.
For vulnerable customers, these outcomes take on a sharper edge. A product designed without consideration of foreseeable harm to vulnerable customers fails the test, regardless of how it performs for the broader population. A support model that works for most customers but creates barriers for those in vulnerable circumstances is not delivering good outcomes.
The Consumer Duty Board Report is where firms are expected to bring this together. Not as a regulatory document prepared for an audience of one, but as a genuine assessment of whether the firm is meeting its obligations to all customers, including those who are most at risk of harm.
Where most reports fall short
The most common gap we see is the difference between activity and outcomes. Firms report what they have done rather than what has changed. The report lists the number of colleagues trained, the number of vulnerability flags recorded, the number of complaints closed within SLA. These are inputs and outputs. They are not outcomes.
An outcome is what the customer experienced. Did the vulnerable customer who disclosed a health condition receive a meaningfully different service? Did the customer in financial difficulty get access to support before their situation escalated? Did the customer who struggled with a digital-only journey find an alternative that worked for them?
If your Consumer Duty Board Report cannot answer these questions with evidence, it is reporting on effort, not on effect.
Another common weakness is the absence of vulnerable customer voice. Reports draw heavily on internal MI but rarely include evidence from the people the Duty is designed to protect. Without solicited and unsolicited insights from vulnerable customers, the report tells the board what the firm measured, not what customers experienced.
What good looks like
The strongest reports we have seen share several characteristics. They draw on solicited and unsolicited insights, not just complaint volumes. They triangulate what vulnerable customers say with what colleagues observe and what the data shows. They are honest about where the gaps sit.
They also connect vulnerability to commercial and operational reality. Consumer Duty implementation is not only a regulatory matter. A firm that understands where vulnerability creates risk in its customer journeys is better placed to reduce conduct risk, lower complaint volumes, and improve outcomes for all customers, not only those in vulnerable circumstances.
We bring bad news when it is there and highlight good practice when we see it. The best firms do the same in their own reporting. They acknowledge what is working, explain where it is not, and set out a plan to close the gap. This is what vulnerability governance looks like when it is taken seriously at board level.
Beyond the annual cycle
The real value of the Consumer Duty Board Report is not the document itself. It is the discipline it creates. Firms that treat it as an annual checkbox produce a report and move on. Firms that treat it as a governance tool use it to drive decisions, allocate resources, and hold themselves accountable for improving vulnerable customer outcomes throughout the year.
The board report should not be the only time vulnerability reaches the boardroom. The firms that embed vulnerability into their governance frameworks, that track customer outcomes continuously rather than annually, are the ones whose reports tell a genuine story of progress.
If your board report currently describes activity, the question is not whether it satisfies the regulator. The question is whether it tells you anything useful about how your vulnerable customers are actually being served.
Let’s talk
If your Consumer Duty Board Report needs to shift from activity to outcomes, a Vulnerability Review can help you assess whether your vulnerable customer journeys are receiving adequate scrutiny and what needs to change. We work across financial services and beyond, from banking and insurance to lending and wealth management.