The Consumer Duty Board Report: What Your Governing Body Must Review, Approve and Sign Off

The rule: what PRIN 2A.8 actually requires

The obligation is set out in PRIN 2A.8 of the FCA Handbook. Under PRIN 2A.8.3R, a firm must prepare a report for its governing body setting out the results of its monitoring under PRIN 2A.9 and any actions required as a result of that monitoring. Monitoring is not optional context around the report; it is the substance the report exists to summarise.

PRIN 2A.8.4R then places three duties on the governing body itself, to be carried out at least annually. The body must review and approve the firm's report on the outcomes being received by retail customers, confirm whether it is satisfied that the firm is complying with its obligations under Principle 12 and PRIN 2A, and assess whether the firm's future business strategy is consistent with those same obligations.

Approval is not a formality. PRIN 2A.8.5R requires that, when approving the report, the governing body must also agree any action needed to address an identified risk that retail customers may not receive good outcomes, any action needed where customers have not received good outcomes, and any amendments to business strategy required to keep it consistent with the Duty. In other words, the board owns the conclusions and the remedial actions, not just the sign-off.

What FG22/5 says the assessment should include

The FCA's finalised guidance FG22/5 puts the rule into plain terms. At paragraph 10.11 it states that a firm's board, or equivalent governing body, should review and approve an assessment of whether the firm is delivering good outcomes for its customers which are consistent with the Duty, at least annually. That framing, delivering good outcomes, is the lens the whole report should be written through.

Paragraph 10.12 lists what the assessment should include: the results of the monitoring the firm has undertaken to assess whether products and services are delivering expected outcomes, any evidence of poor outcomes including whether any group of customers is receiving worse outcomes than another, and an evaluation of the impact and root cause; an overview of the actions taken to address any risks or issues; and how the firm's future business strategy is consistent with acting to deliver good outcomes under the Duty.

Paragraph 10.13 is the sign-off step. Before signing off the assessment, the board should agree the action required to address any identified risks, agree any action required to address poor outcomes experienced by customers, and agree whether any changes to future business strategy are required. Finally, paragraph 10.14 confirms the report matters beyond the boardroom: the FCA treats the assessment as part of the evidence it uses to judge compliance, and expects to be provided on request with the report and the management information that sits behind it.

What the board report must contain

A practical way to structure the report is to work through the four consumer outcomes and then the governance wrap-around. Each outcome section should present the monitoring results, the evidence of good or poor outcomes, and the actions taken and planned, rather than a data dump the board is left to interpret. The table below maps the required content against each area.

The four outcomes named in the Duty are products and services, price and value, consumer understanding, and consumer support. The governance section then does what PRIN 2A.8.4R and 2A.8.5R demand: it records the board's conclusions, its agreed actions, and its assessment of future strategy.

The Consumer Duty champion and the board's role

FG22/5 paragraph 10.10 originally set out an expectation for a board champion. It stated that firms should have a champion at board, or equivalent governing body, level who, along with the Chair and the CEO, ensures the Duty is being discussed regularly and raised in all relevant discussions, and that this champion should be an independent non-executive director where possible. The role was designed to keep senior attention on customer outcomes rather than to write the report.

This expectation has since changed. The FCA has confirmed that from 27 February 2025 it no longer expects firms to have a Duty champion, although firms can retain the role should they wish to do so. Many have kept it, because a named senior owner helps keep the Duty on the agenda between annual reports. Removing the formal expectation does not remove the governing body's underlying accountability under PRIN 2A.8.

Whether or not a firm keeps a champion, the board itself remains responsible. FG22/5 paragraph 10.9 expects the board to ensure the Duty is considered in all relevant contexts, including governance, remuneration policies, and the work of risk and internal audit functions. The report is where that oversight is evidenced. A strong report shows the board asking questions and directing action, not merely receiving a paper prepared elsewhere.

What the FCA praised and criticised

In December 2024 the FCA published good practice and areas for improvement drawn from a targeted review of the first annual board reports from 180 firms across retail banking, insurance, payments, consumer investments, consumer finance and wholesale. The publication is the clearest signal firms have of the standard expected, and it is worth reading in full alongside FG22/5.

On good practice, the FCA highlighted reports that drew clear conclusions from data rather than presenting numbers without commentary, that linked complaint trends to specific events such as technical incidents or process changes, and that included dedicated sections on each of the four outcomes. It valued reports that documented genuine board challenge, evidenced the positive influence of the Consumer Duty champion, and gave specific illustrative examples of action taken, such as removing non-compliant products or changing pricing.

On areas for improvement, the FCA found some firms lacked the data quality to justify their conclusions or to give the board adequate assurance, and relied on high-level claims without explaining how monitoring thresholds were set. It flagged a disconnect where a firm described extensive support for vulnerable customers while its own management information indicated fewer than half were receiving good outcomes. It criticised weak action plans lacking timescales, owners and success measures; reports produced almost solely by compliance or a dedicated Consumer Duty function without wider input; and cases where effective board challenge on the report's content was not evident.

How to produce the annual board report

A repeatable process is what turns the report from an annual scramble into evidence of embedded governance. Start early, base the report on outcomes monitoring you have run through the year rather than data assembled at the last minute, and give the board enough time and detail to challenge before it approves. The steps below outline a workable sequence.

Two points deserve emphasis. First, the report should read as the board's assessment, so involve stakeholders beyond compliance and record the board's questions, challenge and agreed actions in the minutes. Second, keep the management information that sits behind the report, because the FCA can ask for both the report and that MI at any time.

Conclusion

The Consumer Duty board report is a governance obligation with teeth. PRIN 2A.8 requires the governing body to review and approve an assessment of consumer outcomes at least annually, to confirm whether it is satisfied the firm is complying, to assess future strategy, and to agree the actions that follow. FG22/5 fills in what that assessment should contain, and the FCA's review of 180 first-year reports shows the difference between a document that evidences good outcomes and one that merely asserts them.

The firms that do this well treat the report as the visible output of year-round outcomes monitoring, involve people beyond compliance, and record genuine board challenge and clear, owned actions. If you want a single system to run outcomes monitoring, evidence your controls and assemble a board-ready report, see how Nasara Connect Control supports the Consumer Duty, or request a demo to walk through it with our team.

Frequently asked questions