From “Have You Got a Framework?” to “Can You Prove It?”
In 2026, Consumer Duty supervision has shifted from implementation to active testing. According to Browne Jacobson’s review of the FCA’s anticipated priorities, carriers and intermediaries are expected to “clearly evidence how they are delivering good customer outcomes in practice”. A written policy, a governance committee and an annual board report no longer answer that question on their own.
The FCA has also been explicit about where the difficulty lies. It has identified fair value as the single biggest challenge under the Duty for firms with diverse products and extensive distribution channels, as set out in REG’s Fair Value and Consumer Duty guide. If you are a carrier working through MGAs and brokers under delegated authority, that description fits your book closely. You are accountable for outcomes that are produced by firms you do not directly control.
The FCA’s insurance multi-firm review of outcomes monitoring gave the clearest picture of the gap. Many firms were measuring how many product reviews they had completed, not what those reviews revealed about customers. This post covers the tooling gap behind that finding and the five capabilities you need to close it. MGAs and brokers face the same evidencing burden from their side of the chain, so the same capabilities apply to them, but the perspective here is that of the carrier compliance function.
Why Process Evidence No Longer Satisfies the FCA
The FCA’s insurance multi-firm review of outcomes monitoring found firms “reliant on metrics which confirmed the number/percentage of product reviews or value assessments”. That is activity reporting. It shows the process ran, and says nothing about whether customers received fair value, understood their cover or had claims settled properly.
The review also found very little monitoring of whether good outcomes were being achieved in claim settlements, which is where a customer’s experience of an insurance product is ultimately decided. Firms were further criticised for repackaging existing data with limited consideration of the gaps in it. The FCA had already flagged that practice as poor in its January 2023 guidance, so the regulator is signalling that patience with it has run out.
The practical cause is rarely a lack of intent. When your management information (MI) arrives from MGAs and brokers in different formats, on different timetables, through different inboxes, you can only assemble it manually. Manual collation is slow, and it favours the data that is easy to count. Completion rates are easy to count. Outcomes are not. A carrier that relies on spreadsheets will keep producing activity evidence, because that is what a spreadsheet timetable can support.
The Core Capabilities Your Consumer Duty Tooling Needs
Consumer Duty compliance software is only useful if it closes the specific gaps the FCA identified. Five capabilities matter most.
1. Outcomes monitoring, not activity tracking
Your tooling should track claim settlement outcomes, complaint themes and customer understanding, and show how they move over time. A dashboard that reports the number of assessments completed repeats the weakness the FCA criticised. Consumer Duty outcomes monitoring should let you ask whether a product is delivering value and identify the point at which it stops doing so.
2. Fair value assessment workflows
Fair value assessment tools should give you structured, repeatable assessments across product lines and distribution channels, with an audit trail for every decision. A one-off spreadsheet exercise cannot show how a conclusion was reached, who challenged it or what changed afterwards. Where assessments depend on how firms are structured and what risks they carry, configurable frameworks such as REG Risk 365 provide the consistent scoring and thresholds that make assessments comparable.
3. Distribution chain management information
You need to pull consistent MI from MGAs, brokers and coverholders operating under delegated authority, without chasing it by email. Standardised requests, defined response formats and tracked deadlines turn MI from a favour into a controlled process. REG Exchanges supports this kind of centralised visibility and automated workflow across counterparties and distribution chains, including the administration of Fair Value reviews.
4. Vulnerable customer and cohort-level reporting
The FCA review criticised firms for failing to differentiate outcomes by customer group. Averages hide problems. A product can look sound in aggregate while delivering poor results for vulnerable customers or specific cohorts. Your tooling needs to segment outcomes, not only aggregate them, and to show you where a distribution partner’s customer base is faring worse than the rest.
5. Board-ready, audit-ready reporting
New FCA guidance on minimum behaviour standards and senior manager accountability took effect on 1 September 2026. Boards and senior managers must be able to stand behind the Consumer Duty evidence they sign off. That requires structured records that are consistent from one reporting period to the next, traceable to source data and available without a week of preparation. Consumer Duty audit readiness is a property of how data is collected throughout the year, not of how well it is assembled before a review.
Where This Breaks Down Across the Distribution Chain
Evidencing fair value is hardest where money and responsibility move through several firms. Commission and remuneration flow from the carrier through MGAs and brokers under a Terms of Business Agreement (TOBA) or delegated authority arrangement. Each layer takes a share, and the carrier must still be able to show that the product delivers fair value to the end customer once those shares are taken into account.
The FCA continues to scrutinise commission structures and payments to third parties, including in multi-occupancy buildings insurance and premium finance. In both areas it is testing whether payments to third parties can be justified as delivering fair value. The same question applies to your delegated authority arrangements. If you cannot see what each firm in the chain receives and what it does in return, you cannot demonstrate that the price the customer pays reflects the value they get.
This is why distribution chain visibility, more than internal process, is the real bottleneck for carriers. Your internal governance may be sound, but the evidence you need sits with firms you do not control. Contract terms matter here, and REG’s guide to contracts, TOBAs and Consumer Duty explains how agreements can carry the obligations that support evidencing. Knowing who your counterparties are, whether their regulatory status has changed and what they have signed requires reliable onboarding and monitoring, which is the purpose of REG Network.
Moving From Reactive Evidence-Gathering to Embedded Compliance
Many firms still treat Consumer Duty evidence as a periodic exercise. Data is requested before a board meeting, gaps are found late and the resulting report reflects what could be gathered in time. This is reactive, point-in-time compliance, and it is the pattern the FCA’s findings describe.
Proactive risk management inverts it. When distribution chain data is centralised and fair value workflows are automated, evidence accumulates as a by-product of normal operations. REG Technologies built REG Exchanges around this principle: requests, responses, reviews and approvals are logged in one place, so the audit trail exists before anyone asks for it. Combined with continuous counterparty monitoring, this gives real-time visibility of change across the chain and creates a single source of truth for the oversight you carry out.
The effect is a shift from a quarterly scramble to embedded compliance. Your team spends less time collating and more time interpreting what the data says. The technology does not replace judgement or transfer accountability. Your firm remains responsible for its Consumer Duty decisions and regulatory obligations, and the tooling makes those decisions easier to evidence.
The FCA’s bar has moved from “do you have a Consumer Duty framework” to “can you prove it is working”. That shift makes manual, spreadsheet-based evidencing increasingly untenable, particularly across distribution chains where the evidence sits with MGAs and brokers rather than with you. Firms should treat Consumer Duty tooling as core compliance infrastructure, not a periodic reporting exercise. Those that build continuous, audit-ready oversight now will be better placed when the next round of FCA scrutiny arrives.
