Consumer Duty and the Risk of Inconsistent Reporting Standards

When a single adviser produces a slightly different report, it’s easy to pass off as a quirk of style. Multiply that across a team of twenty or fifty, and the same quirks turn into compliance headaches. The FCA’s review of Consumer Duty board reports addresses clearly that inconsistency in reporting risks undermining how firms evidence outcomes, justify charges, and satisfy governance requirements.

How the FCA Assessed Board Reports

From the sample of 180 firms, the FCA noted a sharp divide between well-structured reports and those that faltered. The strongest examples:

• Clear outcomes focus with dedicated sections against all four Duty outcomes.
• Good quality data supporting claims about value and delivery.
• Processes for report production involving multiple business areas, not just compliance.
• Visible culture—leadership setting the tone, staff training tracked, and alignment with remuneration.

By contrast, the weaker reports were often pieced together in isolation, lacking board challenge, or produced without the input of second and third lines of defence. That absence of breadth made it difficult for governing bodies to test conclusions or act with confidence.

The Risk of Fragmentation

In mid to large firms, diversity of adviser styles is inevitable. Some prefer detailed narrative, others concise bullet points. Without a structure that binds these outputs together, variation creeps into suitability reports, annual reviews, and board submissions. The FCA called out better data quality, comprehensive distribution views, and effective action planning as areas too often missing. When every team presents information differently, the board wastes time reconciling details instead of deciding on solutions. It also blurs accountability, making it harder to evidence whether customers truly receive good outcomes.

What Good Looks Like

The regulator’s view of “good” is not uniformity for its own sake. It is clarity, traceability, and alignment. Reports that drew on data strategies with both qualitative and quantitative measures stood out. Boards challenged assumptions, asked for deeper detail on vulnerable customers, and requested clear thresholds for Management Information. In these examples, monitoring was not a tick-box but a live feedback loop.

Implications of Inconsistent Reporting for Larger Firms

Scale amplifies the risk. A firm with 200 advisers cannot afford for each to interpret Consumer Duty obligations differently. Without shared templates, defined processes, and central oversight, the board’s annual report becomes a patchwork that resists scrutiny. The FCA highlighted that the best reports were structured in a way that made them easy for boards to scrutinise key elements. That requires coordination across functions, from compliance to product to distribution.

Moving Forward

The Consumer Duty is not judged on the polish and style of the report. Firms, especially mid and large scale firms, need to be able to demonstrate, with evidence, that their business strategy and delivery align with fair outcomes. That means putting structure around how information is captured, how it is challenged, and how actions are tracked. Quirks of style are harmless at the individual level. At scale, they become signals of risk.

How to Resolve Reporting Fragmentation in Advice Firms

Automwrite resolves this by removing the variability at source. Every adviser works from the same structured framework. Data enters once, flows through to the report, and is stored with a traceable record. The output isn’t just faster — it’s consistent, reviewable, and defensible. For directors and managers, that means a board report built from a single, reliable system rather than a patchwork of individual habits. If you’re responsible for governance and want your team producing to one standard, get in touch and see how quickly you can bring that consistency in-house.

Q&A

Q1. Why does variation in adviser report style create Consumer Duty risk?
Because the board cannot reliably compare like for like. Variation introduces gaps in data, weakens outcome evidence and makes governance checks harder.

Q2. What did the FCA call out in strong board reports?
Clear outcome-by-outcome structure, credible MI, cross-functional input, and visible culture measures such as training, tone from the top and alignment with remuneration.

Q3. What was missing in weaker reports?
Little or no board challenge, siloed drafting, weak distribution views, patchy data quality and unclear action planning.

Q4. How does this show up in suitability reports and annual reviews?
Different advisers emphasise different details. Without a common template, key customer-outcome evidence goes missing or becomes hard to trace across cases.

Q5. What does “good” look like for larger firms?
Clarity, traceability and alignment. Shared templates, standard MI thresholds, defined responsibilities across first, second and third line, and a live feedback loop from monitoring to actions.

Q6. What is the fastest way to de-risk inconsistency?
Standardise at the point of capture. Use one framework for data and narrative, require mandatory fields for Consumer Duty evidence, and automate final outputs.

Q7. How does Automwrite help?
Advisers work inside one structured framework. Data is entered once, stored with a traceable record and rendered into consistent reports. Review is faster, audits are cleaner, and the board sees a single, consistent set of reports built from the same verified data.