Your Consumer Duty board report: the evidence a small brokerage already has

Contents

1. What PRIN 2A.8 actually asks for
2. The FCA has already published the marking scheme
3. What CP26/23 would change, and what it would not
4. Where a small brokerage finds real evidence
5. A twelve-month rhythm instead of a July scramble
6. Frequently asked questions

The Consumer Duty board report is the one Duty deliverable with a date attached to it, and for a brokerage of three to fifty people it is also the one that reliably turns into a fortnight of retrospective evidence-hunting. The rule itself is short. The problem is never the drafting — it is that in July nobody can find data to support the sentence the board is being asked to approve.

There is a better way round, and this year there is an extra reason to look at it: the FCA is consulting on making the whole exercise more proportionate. Knowing what is likely to change, and what certainly is not, is the difference between building a reporting habit and building a document.

What PRIN 2A.8 actually asks for

Strip the commentary away and the requirement is a short list. The firm prepares a report for its governing body setting out the results of its monitoring under PRIN 2A.9 and any actions required as a result. The governing body then, at least annually, reviews and approves that assessment of the outcomes retail customers are receiving, confirms it is satisfied the firm is complying with the Duty, and assesses whether the firm's future business strategy is consistent with acting to deliver good outcomes. It also agrees the actions needed — to address risks of poor outcomes, to fix outcomes that were already poor, and to amend the strategy where necessary.

Note what is not there. No prescribed template, no page count, no submission to the FCA. What is there is a board being asked to say something specific, on the record, about people it has mostly never met. Everything else in this article exists to make that sentence defensible. If the Duty itself is still new to part of your team, the Consumer Duty entry in our glossary covers the four outcomes and the cross-cutting rules in a page.

The FCA has already published the marking scheme

In December 2024 the FCA published its review of the first round of board reports, and updated the page in February 2026 with observations aimed specifically at smaller firms. It reads as a list of what good looks like and, more usefully, of what it kept finding missing:

• Data that does not carry the conclusion. Reports asserting good outcomes without management information capable of supporting the assertion.
• Silence on the distribution chain. Little evidence of information shared with or received from manufacturers and other firms in the chain — a direct hit on brokers, who sit in the middle of it.
• No segmentation. Outcomes reported for the book as a whole rather than for identifiable groups of customers, including those with characteristics of vulnerability.
• No visible challenge. Minutes showing a report was received rather than interrogated.
• Actions without owners. Plans lacking timescales, named owners and a way of telling whether the action worked.

The smaller-firm additions are practical rather than aspirational: use a knowledgeable "critical friend" for impartial challenge where the board is small, lean on external data such as Financial Ombudsman decisions and trade body material where your own volumes are thin, take qualitative feedback from staff and clients seriously as evidence, and use the advantage of a small book — you can test a change and read the result in weeks rather than quarters.

What CP26/23 would change, and what it would not

On 29 June 2026 the FCA published CP26/23, Consumer Duty: scope and proportionality. On board reporting it proposes to make explicit that a firm does not need to produce a standalone Consumer Duty board report: the reporting can be folded into existing governance reporting, sized to the firm's role in the distribution chain, its activities and the risk of harm. The consultation closes on 18 September 2026, with a policy statement expected in 2027.

Two cautions. Proposals are not rules, so the current requirement stands until it does not. And the change on offer is to the packaging, not to the substance — reporting still has to happen at least annually, and it still has to rest on monitoring that actually took place. A firm that reads CP26/23 as permission to stop gathering outcome data has read it backwards.

Where a small brokerage finds real evidence

Most of what the report needs is already inside the business, recorded for an operational reason and never read as Duty evidence. Mapping it once, by outcome, is the work that removes next July from the calendar.

Duty outcome	Evidence a broking firm already holds	Where it lives
Products and services	Which products went to which client types; declinature and claim rejection reasons by product; insurer target market statements you received and acted on	Renewal register, insurer product governance packs, claims log
Price and value	Fee and commission earned against work done; retention against premium movement at renewal; what happened to clients who declined premium finance	Fee agreements, accounts, renewal register
Consumer understanding	The questions clients ask twice; messages that had to be re-explained; complaints citing a misunderstanding of cover; read and reply rates on renewal communications	Shared inbox, complaints log
Consumer support	Time to first response and to resolution; threads left unanswered; out-of-hours gaps; what happened after a vulnerability flag was raised	Shared inbox, diary system, client file notes

The client inbox is the most underused of these. If your servicing conversations run through a shared brokerage inbox rather than personal phones, response times, unanswered threads, opt-outs and repeated questions become countable facts about support and understanding instead of impressions. In ORIS the same layer that runs campaigns from approved templates also produces the segment and engagement data a board can read: which groups of clients answer, which have gone quiet, where risk scores moved. Vulnerability is the segment that most often has no data behind it at all — our note on handling vulnerable customers over WhatsApp sets out what to record at the point of contact so that the number exists in July.

A twelve-month rhythm instead of a July scramble

1. Quarter one: fix the measures. Agree eight to twelve measures, two or three per outcome, drawn from the table above. Write down the source of each and who produces it. Resist inventing a metric you cannot pull without a manual exercise.
2. Quarter two: segment. Split at least three measures by client group — personal versus commercial, tenure, vulnerability flag, product. Whole-book averages were the single most common weakness the FCA identified.
3. Quarter three: read complaints properly. Group them by root cause rather than by outcome, and check the same themes against published Financial Ombudsman decisions for firms like yours. Our guide to when a message becomes a DISP complaint matters here: the expressions of dissatisfaction never logged are exactly the evidence the report is missing.
4. Quarter four: draft, challenge, act. Circulate before the meeting, invite a critical friend to attack the conclusions, and minute the challenge — not just the approval. Every action gets an owner, a date and a way of telling whether it worked.

Done this way the report becomes a summary of decisions the firm already took, which is what the FCA was describing in the first place. If you want to see which of these measures a WhatsApp servicing layer can produce for you, book a demo.

Frequently asked questions

Does a small brokerage really need a separate Consumer Duty board report?

Under the current rules the governing body must review and approve an annual assessment of retail customer outcomes, but nothing prescribes a standalone document, and CP26/23 proposes to say so explicitly. Reporting inside your existing board pack is acceptable provided the four elements of PRIN 2A.8 are clearly there and the minutes show the board engaged with them.

Our board is two directors and an office manager. How do we evidence challenge?

Minute the questions, not the outcome. Record what was queried, what evidence was called for, and what changed as a result. Where the board lacks distance from the operation, the FCA suggests bringing in a knowledgeable critical friend — a compliance consultant or a peer from another firm — and minuting their challenge too.

What if our monitoring found no evidence of harm?

That is a legitimate conclusion only if the monitoring was capable of finding harm. The most common criticism in the FCA's review was data too thin to support the assertion being made. A report that says "no issues identified" alongside three measures and no segmentation invites the question of what you were looking at.

Do we have to send the report to the FCA?

No. There is no routine submission. It is an internal governance record, which means the FCA sees it when it asks — in a supervisory request, a multi-firm review or after a complaint pattern surfaces. That is precisely why the version in the file needs to be the honest one.

Should we pause our reporting until CP26/23 is finalised?

No. The consultation closes on 18 September 2026 and any final rules are expected in 2027, so the existing requirement applies through the current cycle. In any case, the proposal changes how reporting is packaged rather than whether outcome monitoring has to happen.