FCA Consumer Duty Compliance Scorer

What is the FCA Consumer Duty Compliance Scorer?

The FCA's Consumer Duty came into force in July 2023, and 2026 marks the transition from implementation to active enforcement. The FCA has confirmed it will use skilled person reviews (Section 166), formal supervisory tools, and enforcement action against firms of all sizes that cannot demonstrate positive consumer outcomes. From September 2026, SMCR conduct rules are expanding to cover non-financial misconduct, adding another layer of compliance obligation. This scorer automatically assesses your firm across all four Consumer Duty outcomes, identifies gaps with prioritised remediation actions, and generates an evidence pack that satisfies FCA supervision requests.

Built for regulated financial services firms — from IFAs and wealth managers to consumer credit firms and insurance brokers — the scorer replaces subjective self-assessments with data-driven compliance scoring that gives your board and compliance team genuine oversight of Consumer Duty performance.

Who needs this?

• Compliance officers and heads of compliance at FCA-regulated firms
• Independent Financial Advisers (IFAs) and wealth management firms
• Consumer credit firms and lenders subject to Consumer Duty
• Insurance brokers and intermediaries
• Payment services firms and e-money institutions
• Board members and senior managers with SMCR accountability for consumer outcomes
• Compliance consultants advising multiple regulated firms

What's included?

• Automated scoring across all four Consumer Duty outcomes: Products & Services, Price & Value, Consumer Understanding, and Consumer Support
• Cross-cutting rules assessment covering the overarching consumer principle and the three cross-cutting obligations
• Gap analysis with prioritised remediation actions ranked by regulatory risk and implementation effort
• FCA-ready evidence pack generator — produces documentation in the format the FCA expects for Section 166 reviews and supervisory requests
• Board reporting dashboard with trend tracking, outcome metrics, and RAG-rated compliance status
• Vulnerable customer assessment module aligned with FCA's FG21/1 guidance
• Annual Consumer Duty review template meeting the FCA's requirement for at least annual board-level assessment
• SMCR conduct rule mapping showing which senior managers hold accountability for each outcome area

Key Benefits

• Replace subjective self-assessment with quantified compliance scores that stand up to FCA scrutiny
• Identify your highest-risk outcome areas before the FCA does — prioritised remediation saves time and reduces enforcement risk
• Generate board-ready reports in minutes, not days — fulfil the annual review requirement without consuming compliance team capacity
• Prepare for Section 166 skilled person reviews with pre-formatted evidence that demonstrates systematic compliance monitoring
• Track Consumer Duty performance trends over time — demonstrate continuous improvement to regulators
• Map SMCR accountability clearly across all Consumer Duty outcomes, reducing personal regulatory risk for senior managers

UK Regulatory Context

The Consumer Duty (PS22/9) requires FCA-regulated firms to deliver good outcomes for retail customers across four outcome areas. The FCA's 2025/26 Business Plan confirms Consumer Duty as a supervisory priority, with multi-firm reviews planned across retail lending, investments, insurance, and payments sectors. The FCA has publicly stated it will take enforcement action where firms show "serious or persistent failings" and has already issued Dear CEO letters and Section 166 requirements to firms across multiple sectors. The annual board review requirement (PRIN 2A.9) means firms must be able to demonstrate, at least annually, that they are delivering good outcomes — with supporting evidence. Additionally, from September 2026, expanded SMCR conduct rules will cover non-financial misconduct, which intersects with Consumer Duty obligations around firm culture and customer treatment. Fines for Consumer Duty breaches are uncapped and the FCA has signalled its intention to make early, visible enforcement examples.

How it works

1. Configure your firm profile — FCA permissions, customer segments, product types, and distribution channels
2. The automated scorer evaluates your firm against each Consumer Duty outcome using structured assessment criteria, scoring each area on a 0-100 scale
3. Review the gap analysis dashboard, which prioritises remediation actions by regulatory risk and highlights quick wins
4. Generate your FCA evidence pack and board report — updated dynamically as you implement remediation actions
5. Schedule quarterly re-assessments to track improvement and generate the evidence trail the FCA expects for your annual board review

Pricing

£149/month — includes automated scoring across all four outcomes, gap analysis, evidence pack generation, board reporting, vulnerable customer assessment, SMCR mapping, and quarterly trend tracking. Annual billing at £1,499/year (save £289).

⚠️ Legal disclaimer (FINANCE): This product is not financial, tax, investment, or AML advice and SummitBridge Horizon Ltd is not authorised by the FCA. Read the full disclaimer below or in our Terms of Service before purchase.