Consumer Duty has moved decisively beyond its implementation phase and into a period defined by scrutiny and substance. For UK wealth and retirement firms, the emphasis is no longer on demonstrating that processes exist, but on proving that customers are receiving consistently good outcomes.
Kidbrooke, which offers a unified platform for next-generation wealth experiences, has explored why Consumer Duty now demands scalable, evidence-based customer outcome monitoring.
Since the initial implementation deadline passed, the Financial Conduct Authority has sharpened its supervisory focus. In its September update, the regulator indicated that its priorities through 2026 will centre on embedding Consumer Duty across sectors and driving measurable improvements in customer outcomes. This is not simply about frameworks and documentation. It is about whether firms can collect, interpret and act on data that demonstrates fair value, suitable products and clear communications in practice.
That direction has been reinforced through recent supervisory reviews, Kidbrooke noted. In its assessment of insurance firms, the FCA stated that firms must “regularly assess, test, understand and evidence the outcomes their customers are receiving under the Consumer Duty.” The tone signals a shift away from box-ticking exercises and towards a more analytical, insight-driven form of supervision. Outcome monitoring is expected to sit within risk management, governance and product oversight structures, rather than existing as a parallel reporting stream.
For mid-sized wealth and retirement firms, this creates a structural challenge. Many operate with legacy modelling tools, spreadsheet-based projections and manual data processes that were not designed to deliver repeatable, outcome-based evidence at scale.
The result is tension. Firms are expected to demonstrate consistent, defensible outcomes across products, channels and customer segments, yet they may rely on fragmented systems and siloed actuarial or advisory tools, it said. Monitoring frameworks can become overly reliant on process metrics – such as completed reviews or documented assessments – rather than interpretable outcome data that boards and supervisors can meaningfully challenge.
Leading organisations are therefore reframing Consumer Duty not as a time-bound compliance project, but as an operational capability, Kidbrooke said. The focus shifts to strengthening assumptions governance, applying consistent decision logic and ensuring outcomes are traceable and regulator-ready. Industry analysis, including commentary from Deloitte, suggests that success will depend less on manual management information and more on how effectively firms manage and deploy data and analytics.
One approach gaining traction is the development of what some describe as an analytics fabric. This is not a single reporting tool, but a shared analytical foundation governing how assumptions, scenarios and outcome logic are defined and reused. By placing reusable modelling capabilities above core systems, firms can ensure that adviser-led interactions, digital journeys and operational processes all draw on consistent decision rules.
This consistency is critical, Kidbrooke highlighted. Consumer Duty does not assess outcomes in isolation. Boards and supervisors increasingly expect evidence that customer experiences are coherent and repeatable, regardless of the channel through which services are delivered. Fragmented tools and duplicated logic make such assurance difficult, particularly in complex situations such as orphaned client books where adviser relationships have ended but regulatory responsibility remains.
The next chapter of Consumer Duty will be defined not by policies, but by proof, Kidbrooke concluded.
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