In July 2026, the FCA refreshed its multi-firm review of the consumer support outcome, setting out where firms are getting it right and where the gaps remain. Read alongside the other three outcomes of the Consumer Duty, it is one of the clearest statements yet of what the regulator expects firms to evidence, not just deliver, across the customer lifecycle.
As the FCA puts it, firms should provide a level of support that meets customers’ needs throughout their relationship with the firm, enabling them to realise the benefits of the products they buy.
What the FCA Assessed
The review was substantial: a survey of 407 retail firms across banking, insurance, payments, consumer finance and investments, followed by deeper information-gathering across 40 firms. The FCA structured its assessment around four questions, which map almost directly onto the dimensions a robust outcomes testing programme needs to interrogate:
- Meeting customers’ needs: is support effective for all customers, including those with characteristics of vulnerability?
- Access to support: can customers reach support easily, without unreasonable barriers or ‘sludge’?
- Culture, governance and accountability: is good support reflected in strategy, incentives and leadership?
- Outcomes monitoring: what MI and feedback is the firm using to know whether customers are genuinely supported?
The FCA found that some firms relied on transactional metrics such as contact rates and wait times, or waited for complaints to surface issues and relied on traditional process adherence or quality assurance checks. Strikingly, 13% of firms surveyed said they carried out no quality assurance at all on the support channels they offer. In a world where outcomes testing is now the expected standard, this leaves a significant gap for firms to fill.
The Recurring Gap: Judgement, Vulnerability and Evidence
Three themes run through the FCA’s areas for improvement that will resonate with any Consumer Duty lead.
Post-sale support is too often the poor relation
The review warns firms not to focus disproportionately on pre-sales over after-sales support, citing longer wait times for existing customers trying to terminate or downgrade, and challenges firms to make it at least as easy to leave as it was to join. Where support is outsourced, the FCA saw mixed progress on MI oversight, and reminded firms that accountability for the outcome remains theirs whoever delivers the service.
Vulnerability is where judgement matters most
The review highlights innovative work, including vulnerability ‘scores’ built from transaction and chat analytics. But it also makes plain that an empathetic response is not the same as an effective one. The test is whether a disclosure changed the journey. Was the customer routed appropriately, were communication needs met, was affordability reassessed in light of the vulnerability, was foreseeable harm mitigated?
Monitoring needs to look beyond the transaction
This is the crux for any QA and outcomes testing function. The FCA names the tools it expects to see: proactive analytics such as speech analytics in call centres, thematic reviews of the journeys at highest risk of harm, and, tellingly, customer outcome testing programmes which will involve review of customer files, assessing factors such as product suitability, timeliness and availability of support. It distinguishes between monitoring that should be continuous, such as support and complaints data, and deeper work such as file reviews carried out across end-to-end interactions and journeys. Both are expected, and few firms can resource both at the volumes required through manual review alone.
Testing the Whole Support Outcome, Not Just Collections
Assure 4 was designed for precisely this challenge: assessing customer outcomes consistently, at a scale and price point that traditional file-by-file review cannot reach, and converting case-level evidence into thematic insight. Collections is the journey we speak about most often, but it is one of six core customer journeys we have built and can test within the platform:
- Collections and arrears: affordability, forbearance suitability, vulnerability handling and communication strategy.
- Complaints handling: root-cause identification, fairness of resolution and whether the outcome addressed the customer’s actual dissatisfaction.
- Vulnerable customer support: whether disclosure was identified, recorded and translated into tailored support.
- Application, onboarding and sales: target-market alignment, suitability and whether support met the customer’s needs at the point of purchase.
- Servicing and in-life support: accessibility of post-sale support, handling of changes, and parity between pre-sale and after-sale experience.
- Cancellation, switching and exit: the presence of unreasonable barriers or sludge, and whether leaving is as easy as joining.
Point in Time Interactions vs End-to-End Outcomes Testing
The regulator’s language points to two complementary forms of monitoring. By reviewing large volumes of interactions quickly and applying the same criteria to every case, it can surface point-in-time issues or potential harm.
The FCA also references outcome testing that involves the review of individual customer files.
Assure 4 delivers this depth, case by case, producing a structured, evidence-based assessment of whether the outcome was good, where judgement fell short and what the customer experienced across an entire journey. That granularity matters for the highest-risk moments, such as a vulnerability disclosure, a forbearance decision or a complaint, where the quality of the individual outcome, across the end-to-end journey, is what counts.
In practice, firms should use the two together: real-time assurance identifies where a point-in-time interaction is producing poor outcomes, and end-to-end file-level review explains the mechanism across the entirety of the journey.
The importance of testing at scale
It’s unquestionable that the regulator is looking for evidence of outcomes across end-to-end journeys through file testing.
Assure 4 addresses this directly. It looks beyond whether a process step happened and assesses whether that step was sufficient for that customer, in that situation, at that point in their journey, across all six core journeys, at population scale that could be statistically significant.
Our AI-enabled Outcomes Testing solution is significantly more scalable, efficient and effective than manual testing alone (with efficiency gains above 50%).
For firms preparing to evidence the consumer support outcome within their board reports, to their auditors or to the regulator, true end-to-end, statistically significant outcomes testing is now becoming the expected position.
Assure 4 can help you to scale your outcomes testing and assurance activity and unlock customer insights at scale in a cost-effective manner, proving that you truly are delivering good outcomes when they matter most.
If you would like to see how Assure 4 tests any of these six journeys against your own case files, or to walk through a sample file-level assessment, we would be glad to arrange a demonstration.
