It is evident from our reviews that firms are investing significant effort into embedding and evidencing Consumer Duty with a demonstrable commitment to doing the right thing.

Our reviews show that the most successful firms are those who can clearly evidence good customer outcomes, not just through strong narrative, but with robust, quantifiable data and evidence that draws on the FCA’s 2024 publication on Consumer Duty Board Reports: Good Practice and Areas for Improvement.

1. Linking data to good customer outcomes

A common pitfall is the lack of data and metrics that evidence and substantiate the conclusions made. While firms’ reporting commentary is strong, it is often ‘task’ or ‘action’ focussed without underlying quantifiable measures that evidence good customer outcomes and the mitigation of harm. Where data and metrics are provided, many firms continue to rely on measures that are largely predicated on:

• internal processes and operational KPIs (call handling times or average speed to answer)
• compliance and control metrics (monitoring reviews completed to schedule)
• activity volumes (number of vulnerable customers identified)
• static or aggregated data without segmentation (segmentation for vulnerable customers)customer satisfaction & experience (C-SAT scores)

The use of control KPIs and customer satisfaction measures is not sufficient in itself to demonstrate good customer outcomes and the mitigation of harm.

2. Weak outcome to harm frameworks

We believe this often reflects a deeper issue, this being the absence of clearly defined customer outcome statements that are explicitly mapped to foreseeable harms. Without this solid foundation, it becomes difficult for firms to identify meaningful data and metrics that demonstrate how controls are mitigating those harms and how firms are performing against their desired customer outcomes.

Firms that are making the strongest progress under the Duty are those that have invested time in:

• articulating precise outcome statements
• linking them to specific harms; and
• establishing evidence based indicators of success.
• This allows their boards to confidently assess and
• opine upon the effectiveness of controls and
• monitor progress over time with greater confidence.

Firms who partner with Square 4 stand out – showing a clear, evidence-based link between outcomes, harms, and metrics. This isn’t just about meeting regulatory expectations; it’s about building trust, driving growth, and differentiating your brand in a competitive market.

Contact our team at hello@square4.com to discuss how we can help you strengthen your Consumer Duty governance, reporting and outcomes monitoring frameworks, and unlock new opportunities for your business.