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 at least 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. The rules themselves sit in PRIN 2A of the FCA Handbook, introduced by policy statement PS22/9. This guide is a practical account for finance teams, not a compliance opinion. For the broader picture — responsibilities, governance and skills — read our companion guide, FCA Consumer Duty: what it means for your finance function. This page concentrates on the numbers themselves.

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.

A third feature is less often stated but matters just as much: the MI has to be repeatable. The rules require firms to monitor outcomes and review them regularly, so a one-off analysis prepared for a launch or a board meeting is not enough. Whatever finance builds has to run each period, from the same definitions and controls.

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.

What a usable price and value analysis contains

The FCA’s published good and poor practice — for example its review of fair value in consumer finance — repeatedly comes back to the same weakness: assessments that assert value rather than measure it. In practice, a price and value analysis that will stand up to challenge usually includes:

• Total price paid per customer, built from every charge, fee, interest element and ancillary cost, not only the headline price.
• Revenue, direct cost, allocated cost and margin for each product, and for each material customer segment within the product.
• The distribution of outcomes — for example the spread of total cost or margin across customers — so that outliers and cross-subsidies are visible.
• Comparison points: similar products, back-book versus front-book pricing, market comparators.
• The non-financial benefits the product delivers, sourced from product and customer teams, so price is set against benefit rather than against cost alone.

Finance cannot produce the last item alone, but should own the structure. The pricing logic is close to ordinary commercial pricing work — our guide to how management accountants support pricing decisions covers the underlying discipline.

Cost allocation: the build that sits underneath

Every margin figure in the price and value analysis depends on how costs are allocated to products and segments, and this is where most firms first realise how much work is involved. Direct costs such as commissions and product-specific third-party fees are usually traceable. Shared costs — servicing, technology, compliance, premises — have to be spread on some basis, and the basis chosen can move a product from apparently fair value to apparently excessive margin.

Three principles keep the allocation defensible. First, document the method and the drivers used (accounts, transactions, servicing hours, assets under management), so that the board and the FCA can follow how a margin figure was reached. Second, apply it consistently across products and over time; changing the allocation basis in the year a product looks expensive will attract exactly the wrong kind of attention. Third, test sensitivity: show whether the fair value conclusion survives a reasonable alternative basis.

The choice of costing approach is a conventional management accounting decision — see standard costing versus activity-based costing — but activity-based methods tend to suit the Duty better, because the question is what it costs to serve a particular group of customers.

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. We look at why the two functions so often report different numbers in compliance and finance: different numbers.

Outcome metrics finance should be able to join

Metrics vary by sector, but the outcome measures finance should be able to place alongside its own numbers, on a common product and segment key, typically include:

• Products and services: take-up against target market, sales outside the target market, product performance against what was promised.
• Price and value: margin by segment, total cost of ownership, back-book versus front-book price gaps, fee waivers and foregone revenue.
• Consumer understanding: comprehension testing, call reasons indicating confusion.
• Consumer support: resolution times, ease of switching or cancelling, complaints and redress.

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 an 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.

The data the board report needs from finance

Within the annual report, finance is usually responsible for the following data, and should be able to show where each figure came from:

• The conclusions of the fair value assessments completed in the period, with the margin and cost data that supports each one.
• Trend data for price and value metrics by product and segment, on the same basis as the prior year.
• Remediation, redress and fee-waiver costs, linked to the products and issues that generated them.
• The financial effect of repricing, product changes or withdrawals.
• A note of known data limitations and what is being done about them — acknowledged gaps are more credible than incomplete data presented as complete.

Data governance for Consumer Duty MI

Because Duty MI is used to evidence regulatory compliance, it needs the same control environment as other regulatory reporting. The essentials: one product and segment taxonomy shared by finance, compliance and product; a data dictionary; named owners for each source; reconciliation back to the ledger; version control over the allocation model; and sign-off before figures reach the board.

Most firms need agreed definitions and an accountable owner more than new systems. Our pieces on data quality and the finance function and management reporting that gets read cover the wider practice.

A template Consumer Duty MI pack

The table below is a starting structure for the finance-relevant elements of a recurring Duty MI pack. It is illustrative; the right metrics depend on the firm’s products and customers.

Section	Example metrics	Primary owner	Frequency
Price and value	Margin by product and segment; total cost to customer; front-book versus back-book price gap	Finance (FP&A or business partner)	Quarterly
Cost allocation	Cost to serve by segment; allocation basis and sensitivity	Finance (management accounting)	Annual review, quarterly refresh
Charges and fees	Fees charged by segment and channel; variance between similar customers	Finance	Monthly or quarterly
Distribution	Commission and distributor remuneration as a share of total customer cost	Finance with distribution	Quarterly
Redress and remediation	Redress paid by product and root cause; provisions; fee waivers and foregone revenue	Finance with complaints	Monthly
Outcomes overlay	Complaints, switching and cancellation data mapped to the margin hierarchy	Compliance and operations, joined by finance	Quarterly
Data quality	Reconciliation status, known gaps, taxonomy changes	MI or regulatory reporting owner	Each pack

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.

Where no costing model exists, an interim brought in to build, document and hand it over is often quicker than a permanent hire.

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 typically commands a premium over equivalent commercial roles — typically 15–25% — and the Duty has increased demand for the analytical end of it specifically. Our FCA-regulated finance practice covers the market, the regulated firm finance salary guide sets out the benchmarks, and our wider salary guides cover other roles.

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.

For a view of how firms have fared since the rules took effect, see Consumer Duty two years on.

Frequently asked questions

Does the FCA prescribe a format for Consumer Duty MI?

No. The rules require firms to monitor outcomes, review them regularly and report to the board at least annually, but they leave the choice of metrics and format to the firm. The firm has to decide what good evidence looks like and apply it consistently.

How often should Duty MI be produced?

The annual board report is the minimum formal output. Quarterly price and value MI, with monthly redress and complaints data, gives management earlier warning.

Is a fair value assessment the same as a margin analysis?

No. Margin analysis is one input. A fair value assessment weighs the total price the customer pays against the benefits they receive, considering the characteristics of the target market. Finance supplies the cost, price and margin data; the conclusion is a judgement shared with product and compliance.

Has the FCA simplified the Duty?

The FCA has signalled a more proportionate approach — it no longer expects a board-level Consumer Duty champion, and in 2026 it consulted on clarifying scope, including removing non-UK customers and clarifying distribution-chain responsibilities. The core requirements to monitor outcomes, assess fair value and report to the board remain. The companion guide on what the Duty means for your finance function covers the governance changes in more detail.