As the deadline for the next cycle of Consumer Duty board reports approaches on 31 July 2026, the era of tick-box compliance is firmly over. 

For firms regulated by the Financial Conduct Authority (FCA), this report is not merely a mandatory attestation, it’s a critical piece of internal governance and a formal review of how the Duty is being embedded across the business.

The FCA has been clear: ultimate accountability for consumer outcomes sits with boards and senior management. Relying on high-level percentages or vague assertions will no longer suffice.

Focus on High Quality Testing Beyond Readability

It is critical Boards can distinguish between readability and intelligibility in the senior-level Management Information they receive. The FCA has signalled that they won’t trust standard readability scores as a proxy for understanding. 

“Borrowers often struggle to understand complex legal and financial documents, leading to poor financial decisions and confusion. Readability scores alone usually overlook complexity and a user's comprehension….” (FCA).

‍

Relying on readability data alone leaves significant residual risk, as it fails to measure whether a consumer can truly understand and use the information.

Objective intelligibility and comprehension testing is the new standard the FCA expects.

If a Board report relies on readability, is the report compliant?

Firms should have tested all their communications and yet we know they haven’t. The latest update from FCA confirmed as much.

Will your firm be able to provide evidence across all communication asked for by the FCA?

‍
Learning from the Past: Good vs. Bad Practice

Last year’s reporting cycle provided a wealth of insight into the FCA’s expectations. In its recent review of board reports, the regulator identified distinct patterns of good practice:

• Segmented Outcome Monitoring: Stronger reports translated high-level Management Information (MI) into real-world indicators, testing comms, and analysing outcomes for specific customer groups and individual products.
• Proactive Testing: Firms that performed well did not just rely on complaints data. They actively tested communications using validated tools and effective methods, and using tools like comprehension checks to verify understanding.
• Actionable Insights: Good reports clearly documented what was discovered, why changes were made, and the measurable impact of those changes.

The Shift to Richer Data and MI

The FCA is increasingly focused on the quality of MI. Boards are now expected to push beyond simple data points and seek insights that provide a sufficient basis for determining if consumers are truly receiving good outcomes. This shift requires richer data, including information that goes beyond the absence of poor indicators to demonstrate why firms are confident their consumers will achieve good outcomes.

This is particularly relevant for the Consumer Understanding Outcome. Firms must now evidence how they test communications and how they respond when consumer behaviours indicate misunderstanding or friction. Without high-quality data, boards cannot satisfy themselves that the firm is compliant or identify emerging risks.

The Requirement for Board Challenge

A vital element of the 2026 report is demonstrating that the board has not been a passive recipient of information. The FCA expects to see evidence of active challenges driven by quality internal data. They must show that they have questioned whether monitoring is adequate, interrogating deteriorating metrics, and directing corrective actions.

Board minutes should reflect these discussions, as the regulator will scrutinise firms and underlying evidence to ensure the board is taking its obligations seriously. Firms must be prepared to show not just that a process exists, but that the process has been improved through board-level oversight.

How Amplified Global Delivers on Expectations

Meeting these high bars of intelligibility and evidence requires specialised tools. Amplifi supports firms in moving from surface-level readability to deep, validated testing of consumer understanding.‍

• Reporting and our Multi-Level Framework: Our methodology is based on the Amplifi Multi-Level Comprehension Framework to evaluate if consumers can truly apply information to make informed decisions. This helps us to generate the trusted data the FCA demands.

• Diagnostic Tools: Our platform identifies specific intelligibility risks, such as structural and conceptual complexity, that traditional readability scores miss. This provides firms with a clear diagnostic to drive meaningful improvements rather than cosmetic changes.

‍

• Strong Audit Trail: Amplified Global generates an automated, data-driven audit trail of testing results. This evidence is crucial for board reports, providing the robust scrutiny-ready documentation needed for internal governance and regulatory reviews.

‍

‍

‍

‍

‍

‍

‍

By utilising Amplified Global’s methodology, firms can replace vague statements with a clear, well-evidenced narrative on their testing and outcomes. This will ensure their board report is not just a compliance exercise, but a strategic tool for better consumer results.

‍