FCA Consumer Duty

Evidence Consumer Duty, don’t just report it.

Manage the four outcomes, product governance, monitoring, testing, remediation and annual Board reporting through one connected assurance record.

Consumer Duty Assurance Workspace

2026 assurance cycle

Outcome

Price & Value

12 assessments • 2 under review

Outcome

Communications

Understanding tests current

Outcome

Customer Support

1 feedback request

Monitoring

Monitoring breaches

3 open • 1 overdue

Testing

Outcomes testing

8 reviewed • 2 scheduled

Oversight

Board report readiness

82% complete

The challenge

Consumer Duty cannot become an annual spreadsheet exercise.

01

Fragmented product assessments

Product, value and support conclusions sit in separate files and review cycles.

02

Disconnected outcome data

Monitoring and testing evidence is detached from the conclusion it supports.

03

Weak challenge records

Compliance questions and business responses disappear into email chains.

04

Board report scramble

The annual report is reconstructed rather than generated from year-round assurance.

The four outcomes

A structured assurance record for each Consumer Duty outcome.

Products & Services

Evidence product governance and target-market decisions.

Product register, target market, negative target market, distribution, vulnerability considerations and product-review factors.

Price & Value

Demonstrate fair value for the intended customer group.

Nature and quality, limitations, price versus benefits, comparator rates, distribution-chain cost and vulnerable-customer fairness.

Consumer Understanding

Test whether communications support informed decisions.

Clear, fair and not misleading communications, understanding testing, timing and channel appropriateness.

Consumer Support

Evidence support standards and customer outcomes.

Unreasonable barriers, vulnerable-customer support, service standards and monitoring evidence.

Year-round assurance

From product governance to remediation.

Product governance

A live product register for Consumer Duty.

Target market, negative target market, risk rating, product objectives, distribution strategy and review status remain connected.

Outcomes monitoring

Monitor metrics against defined thresholds.

Capture readings, identify breaches, assign owners and connect the result to the relevant outcome assessment.

Outcomes testing

Preserve methodology, findings and review.

Record the test population, approach, evidence, findings, conclusion and independent Compliance review.

Remediation

Turn findings into accountable actions.

Keep the finding connected to its assessment, owner, due date, status, evidence of closure and review history.

Board reporting

The annual Board report is the output of the year-round assurance record.

Board reporting should not be a separate reconstruction exercise. Cerylis brings the evidence, conclusions, challenge, remediation and attestation inputs together throughout the year.

4

Four outcomes

Current assurance status

6

Outstanding assessment links

Awaiting evidence or conclusion

128

Product population

With target-market information

3

Monitoring breaches

Open this period

8

Testing findings

Across outcome testing

5

Open remediation

Board attestation pending

Governance

Clear ownership from evidence to Board oversight.

1st Line

Evidence

Business owners document assessment, monitoring and testing evidence.

2nd Line

Challenge

Compliance reviews conclusions, requests evidence and records sign-off.

Board

Oversight

The Board receives a report grounded in the year-round record.

3rd Line

Audit visibility

Internal Audit can inspect the complete evidence and decision history.

Illustrative workspace · Synthetic records shown
Consumer Duty Capabilities

Everything needed to run Consumer Duty as a continuous assurance process.

Cerylis connects product governance, assessment, customer-outcome monitoring, testing, remediation and Board oversight in one evidence-led workflow. The result is a continuous record of what the firm assessed, what evidence it relied on, what Compliance challenged and what action followed.

DESIGNASSESSMONITORTESTCHALLENGEREMEDIATEREPORTATTEST
The Four Outcomes

Assess the Duty at the level where the evidence actually lives.

Assess products and services, price and value, consumer understanding, and consumer support in a structured record with named ownership, linked evidence, and challenge history.

Products & Services outcome

Define the product proposition, intended market, exclusions, suitability profile, distribution, and review posture.

Illustrative workspace · Product assessment
ProductGlobal Balanced Growth Fund
StatusUNDER REVIEW
Target marketRetail investors seeking long-term capital growth
Negative marketCustomers unable to tolerate capital loss
Risk profileRisk 4/7
DistributionIFA · Direct · Platform
Client categoryRetail
Capacity for lossFull capital loss must be tolerated
ObjectivesCapital growth · Long-term saving
Vulnerability / entity / reviewVulnerability captured, entity mapped, product review tracked

Price & Value outcome

Assess core value factors and retain ownership, evidence, and challenge from 1st and 2nd line.

Illustrative workspace · Fair value factors
Nature / quality / limitationsEVIDENCED
Price vs expected benefitsREVIEW
Costs to manufacture / distributeEVIDENCED
Comparable market ratesEVIDENCED
Total chain costGAP
Target / vulnerable fairnessCHALLENGED
Evidence ownerElena Kowalski
2nd line reviewerMarcus Webb
Fund-specific factorsOptional factors can be added where relevant
ConclusionFAIR VALUE — ACTION REQUIRED

Consumer Understanding outcome

Assess customer-facing communications for clarity, timing, channel suitability, and tested understanding.

NEW CLIENT ONBOARDING WELCOME PACK
AudienceNew advised retail clients
Clear, fair, not misleadingMEETS STANDARD
Tested understandingACTION REQUIRED
TimingMEETS STANDARD
ChannelMEETS STANDARD
Evidence fileCustomer testing results.pdf
StatusFEEDBACK REQUESTED

Consumer Support outcome

Review support quality across channels and service factors, with evidence and open actions.

Illustrative workspace · Telephone support
Supported channelsTelephone · Online chat/messaging · Complaints · Switching/cancellation · Claims · Branch/in-person
Service standardsUNDER REVIEW
No unreasonable barriersMEETS STANDARD
Vulnerable customer supportFEEDBACK REQUESTED
Monitoring evidenceMonthly call QA · Wait-time MI · Abandonment data
Open remediation1
Monitoring

Move beyond the annual assessment.

Monitor firm-wide and linked product, communication and support indicators with threshold review, history and accountable follow-up.

MetricReadingThresholdStatus
Complaint upheld rate3.8%> 4.0%WITHIN TOLERANCE
Average complaint resolution17.2 days> 15 daysBREACH
Annual review completion92%< 95%BREACH
Call abandonment rate4.1%> 5%WITHIN TOLERANCE

Metric flow

ScopeFirm-wide · Product · Communication · Support
Custom metricFirm-defined metric, unit and threshold
Threshold reviewCompliance reviews breaches and records its response
HistoryReadings and status retained over time
FlowMetric → Reading → Threshold breach → Review → Action
Testing

Test whether customers are actually receiving the outcomes your framework predicts.

Testing themes

Theme
Complaints root-cause analysis
Theme
Customer satisfaction / experience testing
Theme
Sales quality / suitability file review
Theme
Switching and cancellation ease testing
Theme
Vulnerable customer outcomes testing
Theme
Price & Value review triggers
Theme
Communication comprehension trends

Q3 2026 · Vulnerable customer outcomes

StatusFINDING IDENTIFIED
MethodologySample of 15 vulnerable-customer journeys
Finding3 customers did not receive expected accommodation
Evidence filesJourney sample.xlsx · Support QA report.pdf
1st line ownerElena Kowalski
2nd line reviewerMarcus Webb
RemediationOPEN
ScopeFirm-level and product-level
Assurance & Governance

Preserve how the conclusion was reached — not just the conclusion.

1st Line AssessmentSupporting Evidence2nd Line ChallengeBusiness ResponseDecisionRemediationClosure

Fair value review dialogue

ER
Elena assessment: “Review data supports the conclusion that the product continues to provide fair value.”
Supporting files: Fee Benchmarking 2026.xlsx · Service Review.pdf · Complaints MI.xlsx
MW
Marcus challenge: “The conclusion refers to comparable market rates but the evidence only covers the firm’s own product range. Please provide an external comparator or explain why one is not reasonably available.”
Elena response: “External comparator analysis added. The product remains within the interquartile range after adjusting for service scope.”
Outcome: FAIR VALUE — ACTION REQUIRED

What the record preserves

Factor evidenceAttached by outcome
Challenge commentsNamed + timestamped
Ownership1st line / 2nd line sign-off
Decision rationaleReason for conclusion retained
HistoryAll revisions retained
Remediation

Turn findings into controlled action.

Remediation tracker

ActionSourceOwnerDueStatusEvidence
IMPROVE VULNERABLE-CUSTOMER REVIEW COVERAGEAscot Financial Planning — Consumer Duty AssessmentElena Kowalski30 Sep 2026OPEN / OVERDUERequired

Action: IMPROVE VULNERABLE-CUSTOMER REVIEW COVERAGE

Lifecycle and rejection path

OPEN → COMPLETION EVIDENCE SUBMITTED → PENDING APPROVAL → 2ND LINE REVIEW → CLOSED
Reject path:
PENDING APPROVAL → SENT BACK TO OPEN
Feature
Closure only with evidence
Feature
Independent approval step
Feature
Reason captured on rejection
Feature
Traceability from finding to closure
Board Reporting

Make the annual Board report the output of the assurance process — not a year-end reconstruction exercise.

CONSUMER DUTY — FY2026 BOARD REPORT

Products & ServicesPrice & ValueConsumer UnderstandingConsumer Support
Report readiness3 product · 1 communication · 2 support outstanding
Outstanding recordsAscot Financial Planning
Horizon Investment Platform
Northbridge Cash ISA
New Client Onboarding Welcome Pack
Complaints Handling Process
Telephone Support Line
Product population rowGlobal Balanced Growth Fund · Target: Retail investors seeking long-term capital growth · FAIR VALUE
Meridian Discretionary Portfolio Service · Target: Advised retail clients · FAIR VALUE — ACTION REQUIRED
Horizon Investment Platform · UNDER REVIEW
Open breaches2
Testing actions3
Remediations4

Reporting features

4-outcome report
Single board pack across all four outcomes
Underlying records
Rows link to source assessments and evidence records
Outcome data + remediation
Live status of breaches, testing and open actions
Drafting and export
AI-assisted drafting with human review + PDF export
Attestation

Evidence what the Board actually reviewed.

Board Review

Entity reviewedNorthbridge Wealth Management Ltd
Reviewed24 July 2026
Minutes fileConsumer Duty Board Minutes.pdf
Recorded byMarcus Webb
StatusACTIVE
WarningThis report has been revised since attestation.

Attestation controls

Attestation record
Named board review and decision record
Multi-entity
Separate records across legal entities
Report snapshot
What was reviewed at that point in time
Revision detection
Flags if report changed after attestation
Controlled correction
Mandatory correction reason retained
Auditability

When someone asks “show me why you reached that conclusion”, have the answer ready.

Assessment report (all fields)

Fields include assessment statement, factor ratings, supporting evidence, challenger comments, response, owner, status and decision rationale.

Evidence pack ZIP tree

CDC-0042-evidence-pack.zip
├─ Assessment report.pdf
└─ evidence/Fee Benchmarking.xlsx
└─ evidence/Service Review.pdf
└─ evidence/Complaints MI.xlsx

Audit log and export CSV

Timestamp · Actor · Role · Action · Summary. Filters: Actor, Action family, Date range. Export CSV for 3rd Line/Admin oversight.

Governed Intelligence

Use AI to reduce the administrative burden — while humans retain the judgement.

Assessment drafting

Prepare first-draft assessment narrative from approved records for user review.

Comparator research

Support market-rate comparison preparation so teams can evidence fair-value challenge responses.

Consistency checks

Flag inconsistent statements across assessment fields and linked evidence before sign-off.

Board report drafting

Assist with board-report narrative assembly from underlying approved records and statuses.

AI assists the work. Accountable users make the regulatory decision.

Roles

Role-aligned workspaces

1st line

Complete assessments, attach evidence, and execute remediation actions.

2nd line

Review submissions, challenge conclusions, and approve or reject closure.

3rd line

Review the audit trail and test whether controls operated as designed.

Admin

Maintain entities and platform configuration for controlled operation.

Feature strip: Review cycles · Trend views · Entity filtering · Bulk Excel import.

Run Consumer Duty as one connected assurance process.

Replace fragmented annual exercises with a continuous, evidence-led process spanning assessment, monitoring, testing, challenge, remediation, reporting, and attestation.

This showcase reflects an illustrative synthetic demo environment.

Who it is for

Built for firms accountable for retail customer outcomes.

Wealth managers • DFMs • Investment platforms • Retail asset managers • Advisers • Other FCA firms within Consumer Duty

Frequently asked questions

Consumer Duty assurance in practice.

Does Cerylis replace our Consumer Duty framework?

Can the four outcomes be assessed separately?

How does Cerylis support the annual Board report?

Can Internal Audit inspect the underlying record?

Explore other solutions

FCA Consumer Duty

Turn Consumer Duty into a continuous assurance process.