FCA Consumer Duty – Looking to 2026

FCA Consumer Duty: Why Manual Monitoring Will Hold You Back

What progress has been made during 2025; what’s next and why Manual processes are holding firms back.

In this blog, we reflect on how far firms have come with Consumer duty over the last 18 months; explore where the main challenges lie and discuss why manual spreadsheets are no longer fit for purpose when it comes to compliance monitoring. Plus how Actus Oversight can help you shift from reactive to proactive compliance.

Why Manual Monitoring is holding firms back

The 31st July 2025 marked a significant milestone for FCA-regulated firms. This was the deadline for demonstrating full compliance with Consumer Duty for all open products and services, with closed book requirements to follow next year in 2026. Yet many firms still rely on manual tracking methods that not only waste time but also run counter to the proactive ethos of the duty itself.

What Is the FCA Consumer Duty?

The FCA’s Consumer Duty represents a shift from traditional rules-based regulation to an outcomes-focused regime. In essence, it is all about consumer protection so it applies to requires firms who support retail customers. The onus is on them to ensure that they offer fair value assessments when promoting or selling their financial products. The FCA’s expects firms to take particular responsibility for ‘vulnerable customers’ and to avoid foreseeable harm for those perceived to be in vulnerable circumstances or financial difficulty.

Firms must prove they are actively working in good faith to:

• Design products and services that meet genuine customer needs
• Deliver fair value across pricing and service
• Communicate clearly with relevant information so customers can make informed decisions

• Provide ongoing support that results in positive customer outcomes

Ultimately, the Duty asks firms to consider: “Are we doing the right thing by our customers?” and not just “Are we compliant?”

What progress has been made during 2025?

In 2025 the FCA’s expectations have been to embed the Duty rather than announcing wholesale new rules. For example, the FCA’s focus areas for 2025/26 included: embedding the Duty across customer journeys; enhancing firms’ outcomes monitoring with a view to creating good outcomes for retail customers; introduction of fair value assessments; and more attention on vulnerable consumers or those in vulnerable situations. FCA+2CMS Law+2

What does a good board report look like?

When the Consumer Duty was launched many firms were scratching their heads about how to write a perfect board report. Some businesses were critical because they didn’t understand what the FCA’s expectations were in this area. However, as the year has gone on, it has become clearer that the FCA expects firms to take responsibility for understanding the consumer duty requirements and applying them in a way that is most appropriate to their market. They are not seeking to be prescriptive about the “How” of the regime as that encourages a ‘tick box’ approach to consumer protection. They want firms to think deeply about how they can increasingly deliver good customer outcomes over time. It isn’t a one and done thing.

That means that a ‘good’ board report is going to vary from one financial service firm to another because it needs to be specific to their market and circumstances. What the FCA has done is publish reviews of board-level reports from firms, pointing good practice (and poor) in how boards are overseeing the Duty. This approach is giving guidance to firms about effective consumer duty implementation and in particular good practice without being overly prescriptive which might encourage ‘tick box’ copy cats. FCA

How are firms responding?

There is evidence that firms are responding: health-checks by law firms and advisers report that firms are stress-testing their implementation of the Duty, including products & services design, customer journeys, and support-outcomes. CMS Law+1

Meanwhile the FCA has signalled a streamlining exercise, having called for senior management input, it is reviewing how the rules and guidance can be simplified, and how prescriptive disclosure and other legacy obligations may be rationalised. However, just because they are not being prescriptive, they are still expecting firms to actively look to evidence improvement against the four outcomes. This is where a solution like Actus Oversight can be invaluable, supporting firms to capture their KPI’s and Improvement actions and track progress on a monthly, quarterly and annual basis. Rather than antiquated spreadsheets Actus Oversight dashboards allow firms to align with the cross cutting rules and four outcomes using clear visual dashboards. This makes it simple for firms to evidence that they are meeting the duty’s standards while also acting as a valuable business tool.

Is the FCA enforcing the regime?

Let’s face it, some firms may still be sitting back because so far, only one overt enforcement case under the Duty has emerged and full public Final Notice cases are still somewhat limited.//www.investmentweek.co.uk/
However, the FCA has publicly confirmed that the Consumer Duty is now part of its enforcement lens and that it expects firms to act to deliver good outcomes and to be held accountable for failures. Legal commentary also suggests that when enforcement under the Duty happens it will focus heavily on the cross-cutting rules (for example “avoiding foreseeable harm”, “acting in good faith”, “supporting customers’ financial objectives”) rather than just the outcome rules alone. UK Finance+1

What needs to be done in 2026?

Looking ahead to 2026, firms will need to move from implementation plans to sustained embedding and improvement of the Consumer Duty requirements across culture, governance, product-lifecycle, and monitoring. Here are some key areas of focus:

1. Board and senior governance oversight:Firms must ensure that their boards receive meaningful metrics and insight into consumer outcomes and that governance is more than compliance-tick. The thematic review shows many board reports are still too high-level. Firms should sharpen insight, set KPIs and escalate issues.
2. Products and services lifecycle:It is not enough to apply the Duty at launch; ongoing monitoring of whether products remain suitable and deliver value is essential. In 2026 firms should embed “outcome thinking” into product design, distribution and review.
3. Fair value and consumer understanding:Firms must ensure pricing, features, hidden costs, incentives and restrictions deliver genuine value for consumers. Communications must enable consumers to make informed decisions. In 2026 more rigorous assessments and dashboards will be needed.
4. Customer journey and support:With vulnerability, digital journeys, distribution chains and indirect relationships all flagged by the FCA, firms need to map and test every touchpoint. They should use data to identify friction, drop-outs, misunderstandings and intervene where customers may be at risk.
5. Data, monitoring and remediation:Firms will need to build, or refine, data infrastructure that shows outcomes, patterns of harm, and whether they are meeting the Duty. Boards expect to see trend-analysis, root-cause and remediation action. Also, early remediation of issues will reduce regulatory risk.
6. Proportionate embedding for smaller firms and distribution chains:The FCA is signalling more support and flexibility for smaller firms. Even so, they must still demonstrate they are meeting expectations in a way that matches their size and risks. Firms in distribution chains (which may not directly interact with retail consumers) still owe duties.
7. Simplification and future-proofing:As the regulator streamlines rules, firms should take this opportunity to simplify architecture, remove duplication, and ensure clarity in roles, responsibilities and governance in anticipation of evolving regulation (e.g., digital/AI risks, cross-border distribution).

The Problem with Manual Monitoring

Despite the scale of this regulatory change, many firms still rely on outdated, manual tracking approaches. Here’s why that’s a problem:

Its slow and labour intensive

Manually entering Consumer Duty metrics into spreadsheets, emailing stakeholders for updates, or consolidating responses for board reports is incredibly time-consuming. These admin-heavy processes drain internal resource and distract from higher-value activity.

You’re relying on lagging indicators

Spreadsheets usually capture what’s already gone wrong: complaints, dropped calls, missed SLAs. These lagging indicators don’t help firms anticipate risk or prevent poor outcomes before they happen which is the core principle of the Duty.

It undermines board assurance

Boards are expected to take ownership of Consumer Duty compliance. But how can they do that with outdated spreadsheets, patchy oversight, or manually compiled reports that may be days (or weeks) out of date?

Manual tools make it hard to demonstrate governance, accountability, or responsiveness- three things the FCA will be expecting from your annual board reports due from July 2024 onwards.

From Reactivity to Proactivity with Actus Oversight

Consumer Duty isn’t just about avoiding non-compliance—it’s about driving better customer outcomes. Actus Oversight supports this goal with purpose-built technology that enables:

Automated ownership and accountability

Assign metrics to specific owners with system-generated reminders and action tracking. Never chase for updates again.

Real-time dashboards and MI reporting

Track performance live with clear, visual dashboards. Use RAG ratings to highlight areas of concern, drill down to root causes, and act before the issue becomes a complaint.

Leading indicators, not just lagging ones

Monitor customer understanding, vulnerability triggers, training completion rates, and other forward-looking metrics that help you predict and prevent poor outcomes.

Audit trails and evidence for the FCA

Easily export evidence of actions taken, outcomes monitored, and gaps closed. Provide your board – and the FCA – with the assurance they need.

The Commercial Case for Proactive Compliance

The FCA wants more than regulatory tick-boxing. The new rules should promote visibility, accountability, and a culture of continuous improvement around good outcomes. This requires firms to be proactive about increasing consumer understanding, avoiding foreseeable harm and to see this as an ongoing process of improvement – a journey, not a destination. Spreadsheets introduce risk in the form of version control and lack of visibility, to say nothing of the administration involved. One off PowerPoint presentations don’t show the journey of improvement and the vision for the future, encouraging a tick-box mentality.

Actus Oversight is a uniquely, affordable SaaS solution that has been specifically designed to support firms to track and manage Consumer Duty proactively.

How it works:

• Tracks firm-specific metrics that are aligned with the four outcomes, cross cutting rules or other aspects of the duty’s standards
• Increases accountability for the duty beyond senior managers and across the firm
• Helps spot early warning signs of value or service failures or poor outcomes
• Allows you to define and cascade specific improvement objectives and report on these throughout the year
• Providing real time evidence that is board report ready, enabling you to demonstrate that you firm is doing the right thing with confidence

With clear Management Information, auditable action tracking and intuitive dashboards, Actus moves you from managing risk retrospectively to proactively safeguarding customer outcomes.

As we move into 2026 the FCA is expecting financial services firms to be embedding better outcomes for retail customer and to be able to demonstrate this. Now is the time to switch from spreadsheet-driven compliance to a system like Actus Oversight designed for dynamic, outcomes-focused oversight.

Actus Oversight enables you to:

• Automate reminders and ownership
• Centralise evidence and audit trails
• Visualise performance in real time
• Focus on fixing gaps – not just reporting on them
• Empower your board to ask the right questions

Conclusion

2025 has been a transitional year for the Consumer Duty: the major milestones are in place, and the focus has shifted to embedding, monitoring and evidencing better consumer outcomes. But embedding culture, board governance, product lifecycle governance and robust monitoring are now the hard yards. In 2026 firms must move beyond “we have implemented the Duty” to “we are living and breathing it — and proving it.” For performance management and compliance software providers (or firms helping organisations do this) there is a clear alignment: embedding the Duty requires strong governance, audit trail, monitoring dashboards and clarity of outcomes. The time for planning is past — the time for sustained embedding is now.

Get Ahead – Book a Demo Today

Consumer Duty is not a one-off compliance exercise – it’s a long-term shift in how financial firms operate. Those who embrace the spirit of the Duty, backed by modern oversight tools, will not only satisfy the regulator but they’ll also build stronger customer trust, loyalty, and long-term business value.

Book a personalised demo of Actus Oversight today and find out how we can help you meet, and exceed, your Consumer Duty obligations.

Actus Oversight – Consumer Duty Software

For more Compliance Resources

Enjoy this blog by Lucinda? See below for more compliance resources available to you.

• Listen now to her new Compliance Culture Podcast series wherever you get your podcasts from…

Apple Podcasts: https://podcasts.apple.com/gb/podcast/compliance-culture/id1852447666

Spotify: https://open.spotify.com/show/5rwSPD896RiPsNBYCpJtT3

Amazon Music: https://music.amazon.com/podcasts/3992bc37-659d-4afe-8f33-9d07ac0ec84b/compliance-culture?ref=dm_ff…

• Download Lucinda’s whitepaper ‘From tick box to trust (Embedding Consumer Duty through Culture Change)’
• Read more Compliance blogs by Lucinda: https://actus.co.uk/category/blog/compliance/