Consumer Duty Internal Audit & Assurance
Moving from "we have a plan" to "we can evidence good outcomes", independent gap analysis, readiness assessment, outcome testing and post-implementation assurance aligned to FCA expectations.
What the FCA is finding
The FCA's thematic reviews since the Duty came into force have been consistent on a small number of points. Documentation is generally adequate; evidence that the Duty has changed how products are designed, communications written, and outcomes monitored is far less consistent. Consumer support monitoring, whether customers who need help can actually get it, at the point they need it, is the outcome most commonly found to be inadequate.
Governance arrangements around Consumer Duty are frequently superficial. Boards are receiving Consumer Duty reports; they are less often receiving reports that contain meaningful outcome data and lead to changes in strategy or product design.
What the FCA expects from internal audit
The FCA has been explicit that internal audit is expected to provide independent assurance over Consumer Duty compliance, and that this assurance should cover the actual delivery of good outcomes, not just the existence of policies and processes.
An audit that checks whether the price and value assessment was completed and approved at the right level tells you something useful. It does not tell you whether the assessment was honest, whether the methodology was sound, or whether the product actually represents fair value for the customers who buy it. The FCA wants internal audit going further.
Our approach
We structure Consumer Duty work in three phases, which can be commissioned individually or as a connected programme. Each phase builds on the last, diagnostic identifies gaps, readiness assurance validates remediation, and ongoing assurance provides the board with independent evidence of sustained good outcomes.
Three phases, from diagnostic to ongoing assurance
Each phase can be commissioned independently or as part of a connected programme.
A rapid assessment against FCA expectations across all four outcomes, governance, MI, product lifecycle, distribution, servicing and vulnerable customers. Output is an actionable RAG-rated report, not a document audit.
Tests whether the firm has a credible implementation plan, adequate resources, clear accountability, and evidence that the Duty is genuinely embedded, not just documented. Specifically assesses whether the board can credibly approve the annual Consumer Duty report.
Provides independent assurance over whether customer outcomes are actually improving. Goes beyond process audits into outcome testing, are customers receiving genuinely good outcomes in practice, not just in policy?
Six core workstreams across all phases
Our Consumer Duty methodology covers the full scope the FCA expects internal audit to address, from governance through to customer journey testing and third-party oversight.
Governance & accountability
Board oversight, Consumer Duty champion, committee reporting structure, escalation pathways and the quality of board challenge. We specifically test whether the board can credibly approve the annual Consumer Duty report, a question the FCA will ask.
Products, pricing & fair value
Fair value assessments, target market definitions, product approval processes, fees and charges, and distribution controls. We assess whether the assessments are honest and methodologically sound, not just whether they exist.
Customer journeys & communications
Sales, onboarding, servicing, complaints, retention and exit, and whether communications are genuinely clear rather than technically compliant. Includes review of digital journeys and comparison against actual customer experience data.
Outcome evidence & MI
Quality of customer outcome metrics, MI dashboards, data integrity, trend analysis and action tracking. We test whether MI actually measures outcomes or merely measures activity, a distinction the FCA draws clearly.
Vulnerable customers
The FCA's expectations on vulnerability are high and specific. We assess whether the firm's definition of vulnerability is workable in practice, whether frontline staff are identifying vulnerable customers accurately, and whether adjustments are genuinely improving outcomes.
Third parties & distribution chain
Oversight of agents, distributors and outsourced service providers, including whether the firm is obtaining adequate outcome data from third parties and whether its contractual arrangements support Consumer Duty compliance.
Concrete, board-friendly deliverables
Every engagement produces outputs that the board and audit committee can use, not just a report to file.
Executive summary with overall opinion
Board-level narrative covering overall position, key risks and required decisions.
RAG-rated gap assessment
Findings mapped to the four FCA outcomes with maturity scoring by theme.
Prioritised remediation roadmap
Actions ranked by regulatory priority with clear ownership and timelines.
Board report & committee pack
Draft board wording and a committee slide pack ready for presentation.
Evidence register
Structured record of what was reviewed and what evidence supports each conclusion.
Action tracker
Live tracker linking findings to management commitments, owners and due dates.
Follow-up validation
Optional targeted re-testing to confirm remediation is operating effectively.
Ongoing thematic programme
Recurring audit coverage for annual plans, one or more outcomes per cycle.
Firms at any stage of the Consumer Duty journey
We work with firms regardless of where they are in their Consumer Duty programme:
- Firms that need an independent view on where they stand before their next FCA interaction
- Internal audit functions that need SME support to deliver credible Consumer Duty audit coverage
- Boards and audit committees that want assurance independent of management's self-assessment
- Firms that have completed implementation work and want outcome testing before presenting to the board
- Firms with closed book products that need to address Consumer Duty obligations now fully in scope
Ready to move from policy to evidenced outcomes?
Whether you need a rapid diagnostic or ongoing audit assurance, we can scope the right work for your firm's situation. A short initial conversation is usually enough to establish what you need.