As firms prepare for their third annual Consumer Duty Board report, expectations are shifting from evidencing governance activity to demonstrating tangible improvements in customer outcomes.
This creates a practical challenge. A Board-ready narrative is not simply a reporting exercise, it relies on disciplined monitoring, testing, remediation and documentation across the first and second lines.
For many firms, the pressure is as much about capacity and capability as it is about content. Challenges often span conduct risk, product governance, customer operations, complaints and quality assurance divisions, to name just a few.
As deadlines approach, access to the right specialist resource – at pace – can make the difference between a report that provides genuine assurance and one that simply collates information.
Here, we unpack five priorities to refine for year three Board report, alongside the delivery roles and resourcing considerations that typically underpin them.
1. Explain what the data says about outcomes – not just what it tracks
Boards need more than dashboards – they need interpretation. Year three reporting should connect indicators to customer experience, explain material movements and be clear on what management has concluded and why.
This often requires specialist capability that is stretched in business-as-usual. For example, conduct MI analysts, customer outcomes specialists, complaints insight leads and second-line reviewers who can triangulate evidence and turn it into a Board-level story. Resourcing plans should allow time for challenge, iteration and ‘so what?’ analysis rather than a late-stage compilation of metrics.
2. Make Board challenge visible and meaningful
The FCA has signalled it wants to see evidence of challenge, not just oversight. Reports are stronger when they show how the Board tested assumptions, interrogated areas of risk, asked for better analysis and influenced priorities and actions.
From a delivery perspective, this is where experienced first- and second-line practitioners add disproportionate value: people who know what ‘good’ looks like, can pressure-test evidence quickly and can help management teams respond to challenge with sharp analysis. Bringing in short-term conduct risk, compliance advisory or Board reporting expertise can help avoid last-minute rework
3. Strengthen oversight of outcomes delivered through third parties
Where intermediaries, ARs, outsourcers or other partners shape the customer experience, Boards need clarity on what outcome-related information is obtained, how it is assessed, where the blind spots are along with and what is being done to address them.
This typically demands dedicated resource to coordinate partner management information (MI), run thematic reviews and follow up remediation – often across procurement, supplier management, compliance and operations. Many firms benefit from bringing in programme support, third-party oversight specialists or QA reviewers to build a repeatable oversight approach ahead of reporting deadlines.
4. Deepen analysis of consumer understanding and support
High-level indicators (such as satisfaction or complaints) rarely tell the full story. Stronger year three reporting shows how testing, behavioural insight and interaction monitoring are being used to assess whether communications support informed decision-making and whether customers get effective help when circumstances change.
Delivering this well often requires specialist roles that may not be consistently available in-house. This can include customer testing practitioners, vulnerability leads, QA and speech analytics subject matter experts and operational teams who can map journeys and identify friction. Resourcing should also cover the ‘fix’ – not just diagnosis – including change and training capability to improve communications and frontline support.
5. Show how Consumer Duty insight is shaping decisions
The most credible Board reports demonstrate a clear chain from insight to action: monitoring identifies risk or weak outcomes, management intervenes, and the firm can evidence whether outcomes improved. This is where Consumer Duty becomes strategic – influencing product design, communications, service and remediation.
In practice, this linkage often fails when teams cannot mobilise quickly enough to investigate, remediate and re-test. Firms should consider whether they have sufficient delivery capacity – conduct change leads, product governance SMEs, operations transformation resource and robust programme management – to turn insight into measurable improvement at pace.
Looking ahead
Consumer Duty Board reporting will continue to evolve as expectations rise and supervision becomes more outcomes-focused. What read as strong in year one or year two may no longer be sufficient for year three.
Momenta support financial services firms with specialist resource and talent when it matters – helping teams build capacity across conduct risk, compliance, QA, complaints, operations and change so they can evidence outcomes with confidence.
If you are approaching your year three reporting cycle and need additional capability to strengthen monitoring, testing or remediation, we can help you mobilise quickly.
