A guide to the Consumer Duty board report
Consumer Duty requires an annual board assessment of whether a firm is delivering good customer outcomes. What it covers, why it matters, and how to prepare.
Consumer Duty requires a firm’s board to review and approve an annual assessment of whether the firm is delivering good outcomes for its customers. For motor dealers and other firms in scope, that means gathering evidence throughout the year rather than producing a document at the end of it.
What the Consumer Duty requires
The Duty sets clear expectations that firms prioritise their customers’ needs - acting in their best interests, providing clear information, and delivering products and services that meet those needs. The obligations sit in PRIN 2A (opens handbook.fca.org.uk in a new tab), with the FCA’s expectations in its final guidance, FG22/5 (opens fca.org.uk in a new tab).
Why it matters for automotive dealers
Trust. Demonstrating a commitment to customer welfare builds the kind of relationship that survives a difficult transaction.
Legal compliance. The Duty is a regulatory requirement, and failing to meet it carries consequences.
Reputation. In a sector under sustained regulatory attention, being able to evidence good practice matters commercially as well as regulatorily.
What the assessment covers
Three areas run through it:
Customer needs. Understanding and prioritising what customers need at every stage of the buying process.
Clear communication. Providing transparent information about products, services and pricing.
Fair outcomes. Ensuring the products and services offered actually meet customer expectations and needs.
How to prepare
Training and awareness. Staff need to understand the principles and how they apply to what they do daily. A board report describing training that did not happen is worse than no report.
Reviewing practices. Sales and customer service practices need regular review against the requirements, with the review itself documented.
Feedback mechanisms. Customer satisfaction data is part of the evidence base. Firms that only start collecting it when the report is due have nothing to report on.
The practical difficulty
The board report is an evidential exercise. A firm that has monitored outcomes through the year can write it in an afternoon; one that has not will find there is nothing to write from. That is the main thing to plan around - the reporting requirement is really a monitoring requirement wearing a deadline.
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