The FCA is no longer asking whether firms have outcomes monitoring frameworks in place. It is asking whether those frameworks actually work.
As supervisory scrutiny under the Consumer Duty intensifies, firms that cannot clearly evidence how data, MI and governance are being used to identify harm, challenge performance and drive change are increasingly exposed, not just to regulatory challenge, but to difficult Board conversations and remediation programmes that come at a real commercial cost.
Consumer Duty is clear: good customer outcomes don’t happen by accident. They are actively designed, continuously monitored, and deliberately managed.
Yet many firms still rely on data and outcomes monitoring frameworks that look robust on paper but fall short in practice. Dashboards are produced, committees meet, and packs are circulated but risks remain undetected, emerging issues go unnoticed, and poor outcomes surface only after the damage is done.
In our recently published White Paper, Outcomes Monitoring: A Square 4 Practical Guide, we explore why this continues to happen and what firms need to do differently in light of the FCA’s 2025/26 Consumer Duty Monitoring review.
The reality behind many outcomes monitoring frameworks
At its core, effective outcomes monitoring rests on three connected pillars:
- Management Information (MI) that evidences outcomes, not just activity
- Data that is accurate, trusted, and consistently defined
- Governance that drives timely challenge, decision‑making, and action
In too many firms, these pillars exist but they don’t work together. Data is fragmented. MI reports the past rather than identifying future risk. Governance reviews information but struggles to translate insight into action. The result is not inactivity, it is false reassurance. Senior leaders believe they have visibility, when in reality emerging risks and deteriorating customer outcomes remain undetected until they crystallise into issues, complaints or regulatory challenge.
With the FCA’s 2025–30 Strategy reinforcing expectations around data, MI, and accountability, this is no longer a tolerable gap. Firms should expect close supervisory scrutiny, not just of what MI is produced, but how it is used in practice to manage risk and improve outcomes.
Pillar 1: MI that informs decisions, not just reports performance
Under Consumer Duty, MI must do more than describe what has already happened. It must provide active surveillance of customer outcomes and highlight foreseeable harm before it crystallises.
Over‑reliance on aggregated operational key performance metrics, for example, volumes, turnaround times, service level agreements, complaint volumes can create a false sense of comfort and easily mask harm. Strong operational performance can easily coexist with poor outcomes for specific customer segments. Firms that don’t look beneath the surface risk missing the very issues Consumer Duty is designed to prevent.
Effective outcomes MI looks beneath the headline numbers, using granular and disaggregated data to answer two critical questions:
- What are customers experiencing today?
- What do emerging trends suggest they will experience tomorrow?
Equally important are clear tolerances and escalation triggers. Firms need to be explicit about what “good” looks like, when intervention is required, and who is accountable for acting. Near‑misses matter. A metric that consistently approaches its tolerance is often a stronger signal than one isolated breach.
Finally, MI without interpretation rarely drives action. Numbers alone don’t drive decisions, context does. Without clear commentary explaining what has changed, why it matters, and what management intends to do, even well‑designed MI will fail to support meaningful governance. This is the most common gap we see in governance packs; the failure to answer the “so what?” question.
Pillar 2: Data quality: the foundation regulators expect you to get right
MI is only as good as the data that underpins it. Yet inconsistent definitions, manual adjustments, and fragmented systems continue to undermine confidence in reporting across many firms.
The FCA’s expectation is not simply that firms produce data, but that they understand it, trust it, and actively use it to manage risk and deliver good outcomes. Where data quality is weak, boards are not just under‑informed, they are often misinformed, making decisions on numbers that feel reliable but are fundamentally flawed.
Left unaddressed, these issues compound. Over time, they erode the integrity of every dashboard, committee pack, and decision built on top of them exposing firms to regulatory challenge and poor commercial outcomes alike.
Under Consumer Duty, data accuracy is not a technical issue, it is a regulatory expectation. Firms must be able to evidence what their data represents, where it comes from, and why it can be relied upon. Poor data quality doesn’t just invite scrutiny; it leads to misplaced confidence and missed risk.
Pillar 3: Governance that closes the loop
Strong governance is not measured by how often committees meet, but by whether insight leads to action and whether that action improves outcomes for customers. That requires:
- Senior leaders who can interrogate MI, not just receive it
- Forums where challenge is expected, not managed away
- Escalation routes that prioritise what matters, quickly enough to act
Regulators are increasingly focused on the evidential trail; what information was reviewed, how it was challenged, what decisions were taken, and what changed as a result. Firms that cannot clearly demonstrate this line from oversight to outcomes will find it increasingly difficult to defend their position under Consumer Duty.
A joined‑up framework or a growing regulatory risk
Data, MI, and governance only work when they operate as a single, connected system. When one is weak, the others are undermined. Fragmented data produces unreliable MI. Backward‑looking MI drives reactive governance. And governance without insight will always struggle to prevent harm rather than respond to it.
Firms that treat outcomes monitoring as a joined‑up framework rather than a set of disconnected compliance activities are far better placed to meet regulatory expectations, make better decisions, and deliver consistently good outcomes for their customers.
How Square 4 can help
We work with firms to assess, design, and strengthen outcomes monitoring frameworks that stand up to regulatory scrutiny and genuinely support senior management decision‑making. From independent reviews aligned to the FCA’s 2025/26 Consumer Duty Monitoring priorities, to practical support improving MI, data quality, and governance effectiveness, we help firms move from compliance to outcomes confidence.
Download our White Paper: Outcomes Monitoring: A Square 4 Practical Guide or start a conversation about how resilient your data and outcomes monitoring framework really is by contacting us at hello@square4.com
Mani Johal
Senior Consultant
