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    FCA undertake multi-firm review into how firms are monitoring outcomes under the Consumer Duty



    Under the Consumer Duty, firms are required to regularly assess, test, understand, and provide evidence of the outcomes their customers receive. As part of their supervisory work, the FCA have undertaken a review of a select group of larger insurance firms to understand their approaches to monitoring outcomes. The FCA’s findings have been published and the report provides examples of good and poor practices that can help all firms improve their outcomes monitoring.

    Multi-firm review

    In December 2023, the FCA requested reports from 20 large insurance firms, including general insurers, life insurers, insurance intermediaries, and regulated third-party outsourcers. Firms needed to demonstrate their monitoring, assessment, and testing of customer outcomes and actions taken after identifying poor outcomes.

    In line with the requirements set out within PRIN 2A.9 and guidance in FG22/5, the review aimed to:

    • Identify themes in firm approaches.
    • Highlight good practices.
    • Assess areas needing improvement.

    The FCA’s review focused solely on outcomes monitoring and excluded assessments of underlying processes or other Consumer Duty requirements.


    The FCA findings expressed that the responses varied in quality, with both good and poor practices observed. Some firms developed clear, comprehensive approaches to monitoring customer outcomes, including:

    • Defined customer outcomes.
    • Clear metrics to monitor outcomes.
    • Identified poor or potentially poor outcomes.
    • Investigated and taking actions.
    • Evaluated customer outcomes with targeted metrics.


    However, the FCA found that many firms need to improve their monitoring to ensure they deliver good outcomes for retail customers. Common issues included a focus on process completion rather than actual outcomes, incomplete metrics, lack of analysis, and insufficient evidence of proactive actions to improve outcomes. Effective monitoring is essential to identify and remediate poor customer outcomes.

    Good & poor practice

    Tips for good and poor practices observed during the review included;

    Design of monitoring approaches

    Firms should define specific outcomes and determine meaningful metrics for monitoring. Good practices included comprehensive metrics and clear approaches to identifying foreseeable harm. Poor practices included reliance on process completion and lack of monitoring.

    Types of data

    Firms need relevant data to assess customer outcomes. Good practices involved a range of outcomes-driven data and frameworks to test outcomes. Poor practices included repackaging existing data.

    Interpretation and scrutiny

    Monitoring information should help understand customer outcomes and enable effective scrutiny and challenge. Good practices included clear articulation and scrutiny of tolerances and integration of second-line challenge. Poor practices involved data that did not facilitate scrutiny or challenge.

    Monitoring different customer groups

    Firms should monitor outcomes for different customer groups, including those with characteristics of vulnerability. Good practices involved differentiated monitoring and insights into outcomes for vulnerable customers. Poor practices lacked differentiation by customer group or characteristics of vulnerability.

    Actions taken by firms to address poor outcomes

    Firms should provide evidence of actions taken after identifying poor outcomes. Good practices included a wide range of data to identify outliers and act to remedy risks. Poor practices had limited evidence of evaluating the impact of changes.

    Next steps

    Firms should review their outcomes monitoring approach against these findings and make necessary improvements. Firms must continually improve monitoring and proactively act to ensure compliance with the Consumer Duty, with a core focus on delivering good customer outcomes.

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