Consumer Duty MI: What Finance Must Produce

The Consumer Duty changed what FCA-regulated firms have to be able to demonstrate, and a large part of the demonstration is data. Boards must satisfy themselves annually that the firm is delivering good outcomes for retail customers, and that assessment rests on management information — much of which finance either owns or is best placed to produce. Yet in a great many firms the Duty is treated as a compliance workstream with finance supplying numbers on request, which produces MI that satisfies nobody and a board report assembled under pressure. This guide sets out what the Duty actually requires by way of MI, which parts finance owns, who builds it, and what it means for hiring.

For the authoritative position, the FCA’s Consumer Duty pages set out the rules and the supervisory expectations, including the requirement for firms to monitor and regularly review outcomes and to produce an annual board report. This guide is a practical account for finance teams, not a compliance opinion.

What the Duty asks for, in data terms

The Duty is built around four outcomes — products and services, price and value, consumer understanding, and consumer support — and firms must be able to evidence that each is being delivered. Two features of that requirement shape the MI. It is outcome-focused rather than process-focused: evidence that customers received good outcomes, not that procedures were followed. And it requires segmentation: outcomes assessed across customer groups, including those with characteristics of vulnerability, rather than in aggregate.

Both features have direct consequences for finance, because the price-and-value outcome in particular cannot be evidenced without financial data that most firms have never had to produce in that form.

The finance-owned pieces

Price and value assessment. This is the outcome most dependent on finance. Demonstrating that a product provides fair value requires the cost of providing it, the revenue earned from it, the margin by product and by customer segment, and the distribution of that margin across the customer base. Firms that have never costed products at that granularity discover the gap quickly — and it is a management accounting problem before it is a compliance one.

Charges and fee data. What customers actually paid, including any variation between segments or channels, and whether identical customers received materially different outcomes on price.

Distribution economics. Where intermediaries or partners are involved, the total cost to the customer across the chain — which requires visibility finance often has and the business often does not.

Remediation and redress costs. Where outcomes were poor, what it cost to put right — both a compliance data point and a P&L one, and a useful leading indicator of where the problems are.

Foregone revenue. Less obvious and increasingly asked for: where the firm chose not to charge, waived a fee or exited a product on fair-value grounds, that is evidence of the Duty operating and it shows up in finance’s numbers rather than anywhere else.

The pieces finance supports rather than owns

Complaints data, customer outcome testing, communications comprehension testing, vulnerability identification and support-channel performance sit with compliance, operations and customer functions. Finance’s role is to make them joinable — complaints by product and segment mapped to the same product hierarchy as the margin analysis, so that the board can see whether the products generating the most complaints are also the ones generating the highest margin. That question is the one boards actually ask, and it cannot be answered if the two data sets use different product definitions.

Which points at the most common practical failure: not missing data, but data that will not reconcile. Compliance counts complaints by one product taxonomy, finance reports margin by another, and the board report becomes an exercise in manual mapping every year.

The board report

The annual board report is where the MI meets its audience, and it is the point at which weaknesses become visible. Three things distinguish reports that work.

They show trend, not a snapshot. Outcomes assessed once tell the board little; the same measures over four or eight quarters show whether the firm is improving.

They segment honestly. Aggregate averages conceal exactly the outcomes the Duty is concerned with. A product delivering fair value on average may be delivering poor value to a identifiable group of customers, and that is the finding the board needs.

They connect the outcome data to the financial data. Margin alongside complaints, price alongside value assessment, remediation cost alongside the product that generated it. Reports that keep the two separate leave the board to make the connection themselves, which is not the point of the exercise.

Practically, this means the board report should be built through the year rather than assembled in the month before it is due — and that the underlying MI should be part of the regular reporting cycle rather than a separate annual exercise. Our guide to board pack preparation covers the general discipline.

Who actually builds it

The answer varies with firm size, and getting it wrong is the source of most of the pain.

In smaller firms, the Financial Controller typically owns the finance contribution alongside everything else, working with a compliance lead. Workable, provided the product costing exists; painful where it does not.

In mid-sized firms, the natural owner is a finance business partner or FP&A function, because the work is analytical and cross-functional rather than transactional. This is the seat most often missing, and its absence is why so many firms produce Duty MI by manual extraction.

In larger firms, a dedicated regulatory reporting or MI function, often sitting between finance and compliance — see our regulatory reporting practice.

The recurring structural problem is ownership: the Duty sits across finance, compliance, product and operations, and where nobody owns the MI end to end it is produced by whoever is available, differently each time. Naming an owner is the single most useful organisational decision a firm can make here.

What it means for hiring

Three practical implications for FCA-regulated firms building this capability.

The skill set is finance plus regulatory literacy, and the combination is scarce. Someone who can do product-level margin analysis is common; someone who can do it and understands what the Duty requires of the output is not. Qualification through ICAEW, ACCA or CIMA is the baseline; the regulatory literacy is what is scarce. Firms that specify only the technical half get analysis that has to be reinterpreted for the board.

Test for the joinability problem at interview. Ask a candidate how they would produce margin by customer segment where the finance system and the customer system use different product definitions. It is the real problem, it is unglamorous, and the answer separates people who have done this from people who have read about it.

And expect to pay a premium. Regulated-firm finance experience carries roughly a 10–15% uplift over equivalent commercial roles, and the Duty has increased demand for the analytical end of it specifically. Our FCA-regulated finance practice covers the market, and the salary guides the benchmarks.

Where firms most often fall short

Product costing that does not exist at the required granularity. The most common gap by some distance, and the one that takes longest to fix — it is a management accounting build, not a reporting exercise, and the costing principles are the ordinary ones the CIMA syllabus covers rather than anything regulatory.

Aggregate reporting that conceals segment outcomes. Averages are the enemy of this regime.

Annual assembly rather than continuous monitoring. The rules expect regular review; a once-a-year scramble evidences the opposite.

Taxonomies that do not reconcile between finance, compliance and product systems.

And no named owner, which produces all four of the above.