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https://www.noxia.co.uk/field-notes/the-board-report-that-proves-nothing · printed from noxia.co.uk · sources checked 24 September 2026

Field note · Advice & compliance

The FCA read 180 board reports. Here is what it said was missing.

A board report is the one Consumer Duty document the regulator is guaranteed to read, and it is usually written in the last fortnight by whoever is free. The FCA has now read 180 of them and published what separated the good from the rest, in unusually plain terms.

4 min read Sources checked 24 September 2026

The short answer

On 11 December 2024 the FCA published findings from a review of 180 firms’ Consumer Duty board reports, including 55 smaller firms, some with fewer than ten employees. It named five areas of good practice and five for improvement. The improvement areas were data quality, distribution-chain evidence, vulnerability analysis, board challenge and follow-through on actions — four of which are about evidence a firm did not hold rather than prose it did not write.

On this page · 6 sections

The annual governing body report is a strange document. It is not filed anywhere. Nobody approves it. Its only reader, in the ordinary course, is the board that commissioned it — and, if things go wrong, a supervisor who will read it as a statement of what the firm knew.

That second reader is why the FCA's review matters. It read 180 of them, across retail banking, wholesale, insurance, payments, consumer investments and consumer finance, and it included 55 smaller firms in the sample, some with fewer than ten employees. This is not a large-firm document.

What separated the good reports from the restGood practice: a dedicated section for each of the four outcomes, commentary backed by good quality management information, analysis of different customer types including those with vulnerability characteristics, a clear production process, and commentary on culture. Areas for improvement: insufficient data quality to justify conclusions, no evidence of information shared across the distribution chain, inadequate consideration of vulnerable customers, no evident board challenge, and action plans without timescales or owners.What good ones didfive practicesA section per outcome, with what good looks likeConclusions backed by management informationDifferent customer types analysed separatelyA process that left time for reviewCommentary on culture, not just complianceWhat the rest were missingfive gapsData good enough to justify the conclusionEvidence of what the distribution chain sharedConsideration of vulnerable customersAny sign the board pushed backTimescales and owners on the actionsWhat separated the good reports from the restGood practice: a dedicated section for each of the four outcomes, commentary backed by good quality management information, analysis of different customer types including those with vulnerability characteristics, a clear production process, and commentary on culture. Areas for improvement: insufficient data quality to justify conclusions, no evidence of information shared across the distribution chain, inadequate consideration of vulnerable customers, no evident board challenge, and action plans without timescales or owners.What good ones didfive practicesA section per outcome, with what goodlooks likeConclusions backed by managementinformationDifferent customer types analysedseparatelyA process that left time for reviewCommentary on culture, not justcomplianceWhat the rest were missingfive gapsData good enough to justify theconclusionEvidence of what the distribution chainsharedConsideration of vulnerable customersAny sign the board pushed backTimescales and owners on the actions
Four of the five gaps are evidence, not prose.FCA, Consumer Duty board reports: good practice and areas for improvement, 11 December 2024.

Read the criticisms carefully and they say the same thing

The FCA's wording on data is the one to sit with: some firms "did not have sufficient data quality to justify conclusions or to give governing bodies adequate assurance". Not "the report was thin". The conclusions were not supported.

On the distribution chain: some reports "did not contain evidence that an appropriate amount and types of information have been shared between the firm and third parties". If you are a manufacturer, what did distributors tell you about outcomes? If you distribute, what did you send back? Most firms cannot show either.

On vulnerability: some firms "did not evidence that adequate consideration had been given to outcomes for different groups of customers". The word is evidence again.

Only the fourth criticism is genuinely about the meeting rather than the data — "it was not always evident that there had been effective challenge from firms' governing bodies". Even that is an evidence problem in the minutes.

A board report is a claim about what the firm knows. Four of the five criticisms are the regulator saying the firm did not know it.

What that means if you are a small firm

The instinct is to write better. The instinct is wrong, and this is the useful finding: you cannot write your way out of a data gap, because the gap is what the reader is checking for.

The work is upstream and it is unglamorous. Decide the handful of outcome measures you will report before the year starts. Capture them as the year runs. Segment them by customer type, including vulnerability, from the beginning rather than at the end. Then the report becomes a summary of something that already exists, written in an afternoon, with the working attached.

That is a pipeline more than it is a policy, and the same argument appears every time a regulator asks a firm to demonstrate rather than assert — it is why we treat the record as the product.

Four questions worth asking in September, not June

  1. Which four numbers describe each outcome for us? Sixteen numbers total. If you cannot name them, the report has no spine.
  2. Are we capturing them now? A measure defined in June covers half a year and proves nothing about the other half.
  3. Can we cut every one by customer type? Including vulnerability, which needs the flag to have been recorded at the time.
  4. What went in and out of the distribution chain? Whatever you sent and received, keep it where the report can reach it.

What this does not tell you

The review is dated December 2024. The FCA has since read 80 second-year reports, and its blog of 16 April 2026 says three things improved — boards formally approving reports and their actions, action plans with owners and timelines, and a wider range of data.

Four still need work: data presented without saying what it shows about outcomes, weak monitoring of distribution chains, board challenge that was not documented, and reports that dwell on products and value more than on whether customers understood and were supported. Three of those four are the first year's evidence problems again, and the FCA says it will consult this year on the distribution-chain rules.

It also does not say how long a report should be, because length was never the complaint.

And it does not help with the harder question underneath: whether the outcomes you chose to measure are the ones that matter to your customers. A firm can measure four things well and still be measuring the wrong four. Targeted support raises exactly that problem in a new form, and the evidence work is where it gets settled.

Questions people actually ask

What must a Consumer Duty board report contain?

The FCA’s December 2024 review found good reports had a dedicated section for each of the four outcomes setting out what good looked like, conclusions supported by good quality management information, analysis of different customer types including those with vulnerability characteristics, a production process allowing proper review and approval, and commentary on culture.

What did the FCA criticise in Consumer Duty board reports?

Five things: insufficient data quality to justify conclusions or give the board adequate assurance; no evidence of information shared with third parties across the distribution chain; inadequate consideration of outcomes for vulnerable customers; no evident challenge from the governing body; and action plans lacking timescales, owners and clarity on data.

How many firms did the FCA review?

180 firms, across retail banking, wholesale, insurance, payments, consumer investments and consumer finance. The sample included 55 smaller firms, some with fewer than ten employees, so the findings are not only about large institutions.

Can a small firm write a good board report without new systems?

Only if it already captures the outcome measures it intends to report, segmented by customer type, throughout the year. The FCA’s criticisms were mostly about evidence rather than writing, and a data gap cannot be written around — the gap is the thing being checked for.

Sources

  1. Financial Conduct Authority, “Consumer Duty board reports: good practice and areas for improvement”, published 11 December 2024. 180 firms reviewed across retail banking, wholesale, insurance, payments, consumer investments and consumer finance, including 55 smaller firms, some with fewer than 10 employees. Five areas of good practice: clear outcomes focus, good quality data, analysis of different customer types, clear production processes, culture focus. Five areas for improvement, quoted: firms that “did not have sufficient data quality to justify conclusions or to give governing bodies adequate assurance”; reports that “did not contain evidence that an appropriate amount and types of information have been shared between the firm and third parties”; firms that “did not evidence that adequate consideration had been given to outcomes for different groups of customers, including those with characteristics of vulnerability”; cases where “it was not always evident that there had been effective challenge from firms’ governing bodies”; and action plans “not accompanied by further details such as timescales, action owners, and clarity on data”. fca.org.uk ↗ — primary; the regulator’s own review of its own requirement re-checked every 6 months
  2. Financial Conduct Authority, Jonathan Pearson, Head of Consumer Policy, “Year 2 Consumer Duty board reports: progress and what comes next”, blog, 16 April 2026: “80 second year reports” reviewed; improvements in governance, action plans and the range of data; still to improve — “Some firms presented extensive data without sufficiently explaining how it demonstrated good or poor outcomes”, “Monitoring of outcomes in distribution chains was often weak”, “Many did not adequately document the challenge they had provided”, and some reports “focused more heavily on products, services and value than on customer understanding and support”; “We plan to consult on changes to rules and guidance relating to distribution chains this year”. fca.org.uk ↗ — primary; the regulator’s own follow-up to its own review re-checked yearly
  3. The observation that four of the five criticisms are evidence problems rather than writing problems, and the four questions, are ours. — our own argument, labelled as such

Checked 24 September 2026. Next scheduled check 23 March 2027. Numbers that move — leaderboards, live indices — are re-checked every 30 days; annual datasets and rules in force every six months; dated research once a year. If something here has gone stale before we got to it, tell us and we will correct it and say what changed.

Cite this note

Noxia, “The FCA read 180 board reports. Here is what it said was missing”, Field notes, 23 September 2026; sources checked 24 September 2026. https://www.noxia.co.uk/field-notes/the-board-report-that-proves-nothing

You cannot write your way out of a data gap.

Name the sixteen numbers — four per outcome — and we will build the capture so that next year’s report is a summary of something that already exists, cut by customer type, with the working attached. The writing then takes an afternoon, which is the only part that ever did.

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Advice & compliance: The FCA read 180 board reports. Here is what it said was missing.

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