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What the FCA Expects Insurance Brokers to Evidence Under Consumer Duty

Last checked 10 October 2026 against the sources below

More than 3 years into the Consumer Duty, the FCA is asking less about policies and more about proof. Here is what brokers need to be able to show.

From Policies to Proof

The Consumer Duty came into force on 31 July 2023 for products open to new customers, and on 31 July 2024 for closed products. Its rules sit in PRIN 2A of the FCA Handbook. The question the FCA now asks is no longer whether a firm has put the Duty in place, but whether it can show that its customers are getting good outcomes across Products & Services, Price & Value, Consumer Understanding and Consumer Support.

What the Annual Board Report Must Show

• The results of the firm's monitoring, including whether its products and services are delivering the outcomes expected.
• Evidence of any poor outcomes, including whether one group of customers, such as vulnerable customers, gets worse outcomes than others.
• The impact and root cause of any poor outcomes.
• The actions taken to put things right.
• Whether the firm's future business strategy is consistent with delivering good outcomes.

At least once a year, the board or equivalent governing body must review and approve the report, confirm it is satisfied the firm is meeting the Duty, and agree any actions needed.

Where the FCA Found Firms Falling Short

The FCA reviewed the first board reports from 180 firms, including 55 smaller firms, and published its findings in December 2024. The weak points it found were:

• Conclusions without the data to support them, such as broad statements that products meet the needs of the target market.
• Vulnerable customers treated as one "catch all" group, rather than looking at different needs.
• Boards that did not visibly challenge the report, acting as a rubber stamp.
• Action plans without owners, timescales or any check that the actions worked.
• Too little evidence from the rest of the distribution chain, including outsourced customer support.

Fair Value Is Under the Spotlight

In its thematic review TR24/2, first published in August 2024, the FCA found that many general insurance firms could not show their products offered fair value. For brokers, that means being able to explain how commission, fees and any add-ons affect the price the customer pays, sharing that information with the insurers whose products you distribute, and checking renewals so loyal customers are not quietly paying more for the same cover.

Complaints and Vulnerability Are Evidence Too

Among the good practice the FCA highlighted was complaints root-cause analysis linked to real events, and using Financial Ombudsman Service decisions to spot harm before it spreads. Complaints and vulnerability records are some of the strongest evidence a broker has, but only if every complaint is recognised and every vulnerable customer is recorded, using the 4 drivers in FG21/1: health, life events, resilience and capability.

What Proportionate Looks Like for Smaller Firms

The Duty applies to firms of every size, but the FCA expects the work to be proportionate. Its examples of good practice at smaller firms included low-cost website analytics, benchmarking against trade body data, and using a "critical friend" to give the board impartial challenge. A small broker does not need a large compliance team. It needs reliable data and a clear record of what it did with it.

A Short Checklist

• Give each of the 4 outcomes its own section in your board report, with data behind every conclusion.
• Explain why you set each threshold in your MI, not just what the number is.
• Look at outcomes for vulnerable customers separately, by driver.
• Record the root cause of complaints, not only the count.
• Give every action an owner, a date and a check that it worked.
• Keep minutes that show how the board challenged the report.

How Omniron Helps

Omniron's Compliance Autopilot links every customer email to the Consumer Duty outcome it affects, and flags complaints and signs of vulnerability as they arrive. Your team confirms each one, and every decision is recorded. That gives you outcome data, complaint causes and vulnerability records for your board report, with a full audit trail behind each figure.