As firms prepare their 2026 Consumer Duty board reports, they’re finding the focus has shifted from implementing the framework to evidencing impact. 

Increasingly, the FCA expects a submission that is coherent, credible and demonstrably tied to customer outcomes. It’s not enough to say the Duty is embedded, firms need to prove it with data, insight and a clear narrative. That takes time. Once you factor in evidence gathering, analysis, drafting, socialisation and approvals, producing a strong report can become a major drain on resource. 

For mid‑tier banks, building societies, and financial services businesses, the challenge is rarely intent. Most do want to do the right thing. The difficulty lies in translating the richness of activity across the organisation into a coherent story that shows the Duty is not only embedded but actively shaping decisions and outcomes. That process takes far more time and coordination than many initially assume which can leave teams scrabbling to hit the FCA deadlines. 

Start early to build a stronger narrative 

The firms producing the strongest reports are those that start early. Consumer Duty touches almost every function in the business, which means pulling together the right information takes longer than a typical annual report or governance paper. Evidence needs to be collected, tested and challenged. And that’s before the report itself is drafted. When teams underestimate the time needed, the result is frequently a report that lacks depth and includes unsubstantiated conclusions. 

Starting early gives organisations room to think. It allows teams to identify what they want the story to be, rather than reverse‑engineering a narrative from whatever data has been collected. It lets them look at customer outcomes from multiple angles and decide which examples genuinely demonstrate progress. And it creates space for constructive feedback and challenge - something that’s much harder to do when the pressure’s on in the final weeks before submission.

Link actions to outcomes with clear evidence 

Perhaps the most important shift in 2026 is the need for firms to evidence actions link to outcomes. The FCA wants to see a clear line of sight between decisions made in the business and the effect those decisions have on real customers. That means evidence matters. Firms need to demonstrate how management information, customer feedback, product reviews, and complaints have driven change. They need to be specific about what improved, why it improved, and how they know. Generic statements risk undermining confidence, both internally and externally. 

Be honest - nobody expects perfection 

Honesty is another hallmark of a strong report. The FCA is not expecting perfection. In fact, reports that present an overly positive picture need to stand up to challenge and scrutiny. Far more credible are submissions that acknowledge where data is still maturing, where cultural barriers remain, or where confidence in outcomes isn’t yet as strong as it needs to be. A willingness to be transparent shows maturity and gives the Board a clearer understanding of the actions required in the coming year. 

Early internal coordination and robust challenge are crucial 

Internal coordination can make or break the process. Consumer Duty reporting can’t sit solely with one team or individual. It must reflect the collective view of the business. Some firms make the mistake of drafting in isolation and seeking input only at the end. A far better approach is to engage stakeholders early - including product teams, operations, customer‑facing colleagues, marketing, complaints. Each group holds a different piece of the puzzle and bringing them together early makes for a more balanced, representative view of progress. 

One area many firms overlook is the need for robust challenge. After two years of operating under the Duty, it’s easy for organisations to become attached to their internal narrative, making structured scrutiny essential. This challenge can come from internal teams, including the second and third lines of defence, who are well placed to test assumptions, surface blind spots, and ensure the story reflects reality rather than aspiration. Ideally, firms should also include an external perspective, which can add an additional layer of independence by benchmarking progress against peers and helping shape a clearer, more compelling narrative. When firms combine strong internal challenge with independent external insight, Boards gain far greater confidence that the report reflects the true picture of maturity. 

Ultimately, improving the Consumer Duty Board Report in 2026 means elevating it above a compliance exercise. The strongest reports aren’t simply repositories of data. They’re thoughtful, evidence‑led reflections of how the firm is learning, maturing, and driving better outcomes for customers. They show where the organisation has made meaningful progress and where it still needs to focus. They support governance, shape priorities, and demonstrate the kind of clarity regulators increasingly expect. 

If your firm wants support shaping this year’s Consumer Duty board report - whether through evidence review, narrative development, or external challenge - the right guidance can turn a difficult task into a strategic opportunity. 

Get in touch

For more information on how the Johnston Carmichael Financial Services team could offer their expertise, or to book one of our Consumer Duty health checks, please contact our Consumer Duty expert, Simon Cavell.