A timetable that starts itself
A recurring annual schedule opens the review months before the board date, and due-date offsets give each product owner a deadline for their evidence. The Tasks grid shows who has not yet delivered.
FCA Consumer Duty Annual Review Checklist Template
The board report is the one Consumer Duty document with a fixed rhythm, and the FCA has now read two years of them. Its feedback keeps returning to thin data analysis, weak oversight of distribution partners and little evidence of board challenge.
This free checklist runs the annual Consumer Duty review at a UK firm, from setting the timetable to the board’s approval. It is for compliance, risk and Consumer Duty leads at banks, lenders, insurers, investment firms, advisers and payment firms. It gathers the evidence on the four outcomes, tests outcomes for vulnerable customers and other groups, and turns it into a report the board can challenge and approve. Two answers at the start add phases only where they apply: closed products, and other firms in your distribution chain. The board’s approval is a recorded task, and the agreed actions carry into next year’s review.
Monitoring, Product Reviews and the Annual Assessment
The Consumer Duty, Principle 12 and PRIN 2A in the FCA Handbook, has applied to open products since 31 July 2023 and to closed products since 31 July 2024. It asks firms to deliver good outcomes for retail customers under four headings: products and services, price and value, consumer understanding and consumer support. Three cross-cutting rules sit over them: act in good faith, avoid causing foreseeable harm, and enable and support customers to pursue their financial objectives.
PRIN 2A.8 requires the firm’s board, or equivalent governing body, to review and approve an assessment of the outcomes customers receive at least once a year. When it does, the board confirms whether it is satisfied the firm is meeting the Duty, considers whether future strategy is consistent with it, and agrees any actions. The annual review is where the year’s monitoring and product work come together, and it does not replace either. A board that only sees the annual report has missed eleven months of chances to act, so many firms also send outcome MI to the board or a committee during the year and use the annual assessment to step back and look at the whole picture.
Ongoing monitoring
All year, PRIN 2A.9
Who: product, operations and compliance teams.
Work: outcome metrics by product and customer group, acted on as issues appear.
Output: MI and fixes made during the year.
Product reviews
Per product, on its own cycle
Who: product owners, with insurers also under PROD 4.
Work: target market, product testing and fair value assessments.
Output: a product kept, changed or withdrawn.
Annual assessment
At least yearly, PRIN 2A.8
Who: the board or governing body.
Work: challenge the evidence across all four outcomes and the strategy.
Output: an approved report and agreed actions.
What the Consumer Duty Annual Review Checklist Covers
Five phases run every year. Closed products and the distribution chain switch on only when the scoping answers in Phase 1 call for them.
Phase 1
Phase 1: Plan & Scope the Review
Owned by the Consumer Duty lead. The answers recorded here decide whether Phases 5 and 6 appear.
- Fix the board date and work back the timetable — many firms kept the 31 July anniversary of the first report
- Confirm the review period and the governing body — the board, or the equivalent body for firms without one
- Refresh the inventory of retail products and services — open and closed, with the target market and the firm’s role for each
- Record whether the firm has closed products with existing customers — a Yes opens Phase 5
- Record whether other firms manufacture or distribute your products — a Yes opens Phase 6
- Agree the outcome metrics and data owners — for each outcome, split by product and customer group
- Carry forward last year’s board actions — each with its owner and status
Phase 2
Phase 2: Products & Services, Price & Value
Outcomes 1 and 2. Product owners supply the evidence; the Consumer Duty lead checks it.
- Confirm each product still meets the needs of its target market — and investigate sales outside it
- Record product changes, launches and withdrawals in the year — with the testing done before each one
- Confirm fair value assessments are current — price against benefits, quality and limitations, including all fees and charges
- Compare price and value outcomes across customer groups — for example long-standing customers, or fees that fall mainly on customers in difficulty
- List products where value is in doubt — with the action: reprice, change, withdraw or redress
Phase 3
Phase 3: Consumer Understanding & Support
Outcomes 3 and 4. Marketing, servicing and complaints teams supply the evidence.
- Summarise testing of key communications — what was tested, what customers understood and what changed as a result
- Check understanding at the moments that matter — sale, price or term changes, renewal and arrears
- Measure support outcomes — wait times, abandonment, first-contact resolution and time to complete common requests
- Test that switching, cancelling and complaining are as easy as buying — and record any friction found
- Analyse complaints MI and root causes — trends, uphold rates and ombudsman outcomes by product
Phase 4
Phase 4: Vulnerable Customers & Cross-Cutting Rules
- Compare outcomes for customers with characteristics of vulnerability against other customers — on the same metrics, not a separate narrative
- Check outcomes for other groups with different needs — for example by channel, age or product holding
- Review how vulnerability is identified, recorded and acted on — staff training, flags and adjustments made
- Test the cross-cutting rules — good faith, foreseeable harm and support for customers’ financial objectives
- Record harm identified in the year and the remediation — customers affected, redress paid and what was fixed
Phase 5 — Closed Products Only
Phase 5: Closed Products
Shown only when the firm has closed products with existing customers.
- List closed products and customer numbers — including books acquired from other firms
- Assess value for closed-book customers — against what similar customers get on open products
- Review communications to closed-book customers — still accurate, understandable and reaching them
- Decide the action for each closed product — keep, change terms, migrate customers or remediate
Phase 6 — Distribution Chains Only
Phase 6: Distribution Chain
Shown only when other firms manufacture or distribute your products.
- Map each firm in the chain and its role — manufacturer, distributor or both, and who influences which outcome
- Confirm the information each party has shared — target market and fair value from manufacturers; sales, complaints and outcome data from distributors
- Review due diligence on partner firms — proportionate to your role and the risk of harm
- Record issues raised with partner firms and how they were resolved — and any that need the board’s attention
Phase 7
Phase 7: Board Report, Challenge & Approval
The approval task is assigned to the board chair or company secretary, who records the board’s decision. A Not approved returns the report to the Consumer Duty lead.
- Draft the assessment — results of monitoring, where outcomes are good and where they are not, with evidence and actions
- Independent review of the draft — second line or internal audit checks the evidence supports the conclusions
- Circulate to the board with time to read it — and record the challenge made in the meeting
- Board approval — satisfied the firm complies, future strategy consistent with the Duty, actions agreed
- Log each agreed action with an owner and due date — they open next year’s review in Phase 1
- File the approved report and minutes — the FCA can ask for them; firms do not submit them
Consumer Duty Requirements Map
Each phase maps to a part of PRIN 2A or the FCA’s guidance. Which parts apply, and how deep the review goes, depends on your retail business and your role in the chain, so treat the table as a starting point, not legal advice.
| Requirement | Source | What the review evidences | Phase |
|---|---|---|---|
| Products and services | PRIN 2A.3; PROD for insurers and investment firms | Products meet the target market’s needs and reach it | 2 |
| Price and value | PRIN 2A.4 | Fair value assessments, by product and group | 2, 5 |
| Consumer understanding | PRIN 2A.5 | Communications tested and understood | 3 |
| Consumer support | PRIN 2A.6 | Support that works and no unreasonable barriers | 3 |
| Cross-cutting rules | PRIN 2A.2 | Good faith, harm avoided, objectives supported | 4 |
| Outcomes for different groups, including vulnerable customers | PRIN 2A.9; FG21/1 vulnerability guidance | Group-level outcome data | 4 |
| Distribution chain | PRIN 2A, applied to each firm’s role in the chain | Information shared and acted on | 6 |
| Annual board assessment | PRIN 2A.8 | Approval, strategy check and agreed actions | 7 |
The Duty is being simplified, but most of the changes are still proposals. The timeline shows what has happened and what is pending.
27 February 2025
No separate Consumer Duty champion expected
The FCA said it no longer expects firms to have a board-level champion, though firms may keep the role.
30 September 2025
Four-point plan
In a letter to the Chancellor on wholesale firms, the FCA committed to clarify its supervisory approach, consult on how the Duty applies through distribution chains, and propose removing business with non-UK customers from scope.
24 February and 16 April 2026
Board report findings
The FCA added insight for smaller firms, then published observations on the first two years of board reports, pointing to gaps in data analysis, oversight of third-party distribution and evidence of board challenge.
29 June 2026
CP26/23: scope and proportionality
Proposals to limit the Duty mainly to customers usually resident in the UK, replace co-manufacturing with a principal and secondary manufacturer model, confirm proportionate due diligence on partner firms, and say a stand-alone board report is not required if proportionate reporting reaches the board at least annually. Consultation closed on 18 September 2026.
Expected early 2027
Final rules
Until the FCA publishes a policy statement, the current PRIN 2A rules apply, including the annual board assessment.
Why Run the Consumer Duty Review in CheckFlow?
Evidence attached to each outcome
Fair value assessments, testing results and complaints MI attach to the task they support, and a data set of your products feeds the dropdowns. When the board asks where a conclusion came from, the evidence is one click away.
Board approval on the record
The board’s decision is an approval task assigned to a named person, and the checklist cannot close until it is answered. The agreed actions and the timestamped activity trail export for the FCA if it asks.
CheckFlow is not a board portal, data warehouse or MI dashboard, and it does not write the report for you. It runs the workflow around them: who supplies each piece of evidence, by when, who reviewed it and what the board approved. Our guide to financial services workflow automation covers other recurring reviews, and the financial services overview shows how regulated firms use CheckFlow.
Complaints MI is one of the strongest outcome signals, and the Complaints Handling Checklist records a root cause for every complaint. Accountability for the Duty runs through your Senior Managers’ responsibilities, which the SM&CR Annual Certification Checklist keeps current, and CheckFlow’s compliance checklist software covers the rest of the compliance calendar.
Frequently Asked Questions
What must the Consumer Duty annual board report include?
The rules require an assessment of whether the firm is delivering good outcomes for retail customers, based on its monitoring, and the actions needed where it is not. The board must review and approve it, confirm whether it is satisfied the firm is complying with the Duty, consider whether future strategy is consistent with it, and agree any actions. The FCA sets no format, but its reviews favour reports built on outcome data, split by customer group, with clear owners for each action.
When is the Consumer Duty board report due?
At least once a year. The first report was due by 31 July 2024, and many firms have kept that anniversary, but the rule sets a frequency rather than a calendar date. Choose a date that fits your board cycle and your data, and keep it consistent so each report covers a full year.
Do we have to send the board report to the FCA?
No. It is an internal governance document, not a submission or an attestation. The FCA can ask to see it, often during supervisory work, so keep the approved version, the minutes showing the board’s challenge and the evidence behind it.
Is the FCA removing the Consumer Duty board report?
Not the annual assessment. CP26/23, published in June 2026, proposes that firms need not produce a stand-alone Consumer Duty report and can fold proportionate reporting into existing governance, as long as the board still considers it at least annually. The consultation closed on 18 September 2026 and final rules are expected in early 2027. Until then the current rules apply.
Do closed products need to be in the annual review?
Yes. The Duty has applied to closed products and services since 31 July 2024, so long-standing customers on legacy products need the same outcome evidence as customers on open products. Value is often the weak point, because closed books can drift from what new customers are offered.
How should the review cover vulnerable customers?
By comparing outcomes, not by describing policies. The monitoring rules ask firms to check whether different groups of customers, including those with characteristics of vulnerability, get worse outcomes than others. Run the same metrics for customers flagged as vulnerable as for everyone else: complaints, arrears, cancellations, time to resolve and value. Where the numbers differ, the report should explain why and what the firm is doing about it. The FCA’s FG21/1 guidance covers how to identify vulnerability and adapt service.
Is CheckFlow free for this template?
14-day free trial, no card required. The Business plan is $10 per user per month after the trial. Full details at checkflow.io/pricing.