Consumer Duty: Governance and Monitoring

Governance and Monitoring [PRIN 2A.9]

Rule: Firms must have appropriate governance arrangements and monitor customer outcomes to ensure the Duty is embedded and delivering good outcomes.

Board Responsibilities

Requirement	Detail
Board champion	Designated individual accountable for Duty
Annual review	Board must review and approve outcomes assessment
Strategy	Consumer outcomes central to business strategy
Culture	Foster culture focused on good outcomes
Resources	Ensure adequate resources for compliance

Outcomes Monitoring

Required Metrics

Firms must monitor outcomes across all four outcome areas:

Outcome	Example Metrics
Products/Services	Target market fit, product reviews
Price/Value	Fair value assessments, comparisons
Understanding	Communication testing, comprehension
Support	Wait times, resolution rates, complaints

Data Requirements

• Segment by customer characteristics
• Identify outcomes for vulnerable customers
• Compare actual vs expected outcomes
• Track trends over time

Annual Board Report

Must include:

1. Outcomes assessment — Are customers getting good outcomes?
2. Evidence base — Data supporting conclusions
3. Actions taken — How issues were addressed
4. Future plans — Improvements for coming year
5. Vulnerable customers — Specific outcomes analysis

MI and Reporting

Report Type	Frequency	Audience
Outcomes dashboard	Ongoing	Management
Deep dives	As needed	Committees
Board report	Annual	Board
Regulatory	As required	FCA

Culture and Training

Requirement	Implementation
Tone from top	Leadership commitment visible
Training	All staff understand Duty
Incentives	Aligned with good outcomes
Accountability	Clear ownership
Escalation	Routes for concerns

Documentation

Firms must retain records of:

• Governance framework and decisions
• Outcomes monitoring data and analysis
• Board reports and minutes
• Actions taken to address issues
• Fair value assessments

Citation

PRIN 2A.9 — Governance and culture FG22/5 — Final non-Handbook Guidance