Findings & Industry sentiment:

• 49%
  of 484 senior financial services professionals state that ‘testing whether communications improve comprehension’ is the hardest area of consumer understanding for their firm to evidence.

• 20%
  state ‘demonstrating governance and ownership of the outcome’.

• 18%
  state ‘using MI and customer insight to drive design changes’.

• 13%
  state ‘adapting journeys for vulnerable or low-capability customers’.
  

Findings & Industry sentiment:

In rank order, 484 senior financial services professionals state they use these methods to evidence consumer understanding to the Board:

• 1(Lead Answer)
  Sales, complaints, and operational MI (86%).

• 2
  Comprehension testing of communications and journeys (38%).

• 3
  Frontline staff competence and decision-quality data (29%).

• 4
  Behavioural and drop-off data segmented by customer group (22%).

Findings & Industry sentiment:

• 69%
  of 485 senior financial services professionals state they are ‘fairly confident [about their Year 3 Report], but there are gaps they know they need to close’.

• 19%
  state they are ‘uncertain, I don’t know what I don’t know, or I'm not sure our report will stand up to scrutiny’.  

• 7%
  state they are ‘not confident, we have significant work to do’.

• 2%
  state they are ‘very confident, we know what good looks like and we're on track’.
  

• 2%
  state they are ‘not sure’.

Findings & Industry sentiment:

In rank order, 485 senior financial services professionals state how aligned they are to making changes to their Board reports based on published FCA reviews:

• 1(Lead Answer)
  Work in progress, we know what needs doing. 

• 2
  Partially, some gaps are closed, others are still open.

• 3
  Yes, we’ve made meaningful changes that we can evidence.

• 4
  Not yet, it’s on the list.

• 5
  Honestly, we’re not sure where we stand or where to start.

Findings & Industry sentiment:

• 58%
  of 470 senior financial services professionals state that the two disciplines of employee competence and outcomes testing are ‘partially connected, some overlap but not consistent or joined-up’.

• 28%
  state they are ‘largely separate, they run independently of each other’.  

• 9%
  state they are ‘not sure how connected they are’.

• 6%
  state they are ‘fully connected, we already link learning and outcomes testing systematically’.

Findings & Industry sentiment:

In rank order, 470 senior financial services professionals state that these are reflective descriptions of their Management Information at present:

• 1(Lead Answer)
  We have data but not conclusions.

• 2
  We track activity but not outcomes.

• 3
  We are in good shape.

• 4
  We identify issues but cannot show we fixed them.

• 5
  Our MI lacks thresholds and rationale.

Findings & Industry sentiment:

• 42%
  of 470 senior financial services professionals state that they would provide ‘a mixture of activity-based and outcomes-based evidence that wouldn’t tell the whole story’ to the FCA if the regulator asked for evidence of outcomes. 

• 33%
  state they would provide ‘good outcomes evidence’.  

• 21%
  state they would provide ‘activity evidence showing process completions and controls rather than outcomes’.

• 4%
  state they are ‘not sure’ what they would provide.

Findings & Industry sentiment:

In rank order, 706 senior financial services professionals state that the top five cultural factors creating the greatest risk to customer outcomes in their firms are as follows:

• 1(Lead Answer)
  Poor ownership of recurring problems.

• 2
  Commercial pressure overriding good judgement.

• 3
  Weak escalation of customer issues.

• 4
  Incentives that drive the wrong behaviours.

• 5
  Lack of challenge and psychological safety.

Findings & Industry sentiment:

• 56%
  of 706 senior financial services professionals state that ‘monitoring outcomes with meaningful data’ is the hardest aspect for their firm to evidence under Consumer Duty. 

• 16%
  state ‘defining what “good customer outcome” looks like’. 

• 15%
  state ‘proving governance challenge and oversight’. 

• 13%
  state ‘aligning incentives and behaviour with the Duty’.

Findings & Industry sentiment:

• 8%
  of 720 senior financial services professionals state they ‘can clearly evidence how culture drives decision-making and customer outcomes in practice’. 

• 33%
  state they ‘rely mainly on policies, training completion and engagement surveys’. 

• 43%
  state they ‘combine culture metrics with some outcome testing and MI’. 

• 16%
  state they either ‘haven’t tested this’ or ‘know it’s a weakness’ that requires remediation.

Findings & Industry sentiment:

In rank order, 720 senior financial services professionals state that the top five biggest conduct and culture risks to delivering good customer outcomes in their firms are:

• 1(Lead Answer)
  Culture exists on paper but doesn’t shape day-to-day decisions.

• 2
  The firm hasn’t clearly articulated what “good outcomes” actually look like in practice.

• 3
  We lack credible evidence that culture supports fair value and good customer outcomes.

• 4
  Accountability is unclear when outcomes fall short.

• 5
  Leadership strategy and priorities don’t consistently reinforce good outcomes.

Findings & Industry sentiment:

• 25%
  of 410 senior financial services professionals state that they are ‘not confident or unsure’ that they could credibly provide evidence of control effectiveness if challenged by the FCA. 

• 57%
  state they are ‘fairly confident but gaps remain’. 

Findings & Industry sentiment:

In rank order, 536 senior financial services professionals state that the top five challenges in turning customer feedback into meaningful business change are as follows

• 1(Lead Answer) 
  Cultural resistance: Staff and leadership don’t prioritise feedback-driven change.

• 2
  Lack of ownership: No clear responsibility for acting on feedback.
  

• 3
  Poor follow-through: Actions are started but not sustained or embedded.
  
  

• 4
  Too much manual process: Time spent on activities which add no value or insight.
  
  
• 5
  Weak analysis: Struggle to identify real themes or root causes.
  

Findings & Industry sentiment:

• 62%
  of 536 senior financial services professionals state that their customer feedback processes are ‘not yet robust enough’ to provide evidence to satisfy Consumer Duty outcome testing. 

• 34%
  state they are ‘fairly confident’.
  

• 4%
  state they are ‘very confident’.
  

Findings & Industry sentiment:

• 75%
  of 584 senior financial services professionals stated they are "not at all, slightly, or only somewhat confident" in their ability to generate the appropriate data/MI to meet ongoing Consumer Duty obligations.

Findings & Industry sentiment:

• 26%
  of 783 senior financial services professionals state they are ‘not at all or only slightly confident’ in their frontline staff's ability to recognise and respond to vulnerability.
  

• 69%
  state they are ‘fairly or predominately confident’.
  

• 5%
  state they are ‘very confident’.

Findings & Industry sentiment:

• 52%
  of 753 senior financial services professionals identified data quality as their primary obstacle when compiling Consumer Duty Board Reports.