On 27 July 2026, the FCA published Outcomes monitoring: good practice and areas for improvement. It sets out findings from a review of how financial services firms track whether customers are getting good outcomes under the Consumer Duty.

This is not new guidance. It is part of the FCA's Good and Poor Practice series, illustrating existing expectations under PRIN 2A with real examples. But the findings are a useful benchmark for any firm assessing its own monitoring approach.

What the FCA reviewed

The FCA assessed board reports and information requests across firms of different sizes and sectors. It also surveyed 56 firms on their strategy, data and MI, and governance for outcomes monitoring.

The review covers monitoring across all four Consumer Duty outcomes: 

1. Products and Services
2. Price and Value
3. Consumer Understanding
4. Consumer Support 

The FCA is clear that collecting data or reporting MI is not enough on its own. Firms must show what the data tells them, how they acted on it, and whether that action improved outcomes.

The four key findings

The FCA identified four traits shared by the strongest monitoring approaches.

Firms that fell short tended to describe monitoring at a high level. They could not show how information led to a decision, or whether an action actually fixed the underlying problem.

Where communications fit in

Consumer understanding is one of the four Consumer Duty outcomes the FCA reviewed. But the review shows that unclear communications are a risk factor across all four, not just for understanding outcomes.

If a customer does not understand a product's features or fees, it is a product and service risk. If they cannot judge whether they are getting fair value, that is a price and value risk. If they cannot follow how to get support, get it wrong, or use it too late, that is a consumer support risk. Poor comprehension does not stay contained to one outcome. It affects a customer's ability to judge and act on all of them.

The FCA's review includes a direct example of this connection. One firm piloted an AI-based tool to test whether its communications confused or misled different customer groups. The tool produced a comprehension score and a risk matrix, and its outputs closely matched findings from human testing. The FCA cites this as good practice in using improved data and testing to strengthen outcomes monitoring.

The review also flags a recurring weakness relevant to communications teams: firms setting arbitrary thresholds and targets without being able to explain what those thresholds are based on, or why they indicate a good or poor outcome. A readability score or a reading-age target has the same problem if a firm cannot show how it relates to consumer outcomes.

What this means for firms

Three findings apply directly to how firms manage consumer understanding - across all communications from marketing communications, legal contracts and customer support.

Define what "understood" means, per document. The FCA rewards firms with clear, evidenced definitions of good outcomes, not broad statements. A single "plain language" policy is not enough. Firms need defined, testable standards for what an intelligible document looks like, applied consistently across a portfolio.

• Show the audit trail, not just the score. The FCA repeatedly criticised firms that could not show how MI led to a decision, an action, and a measured improvement. A one-off readability check at sign-off does not create that trail. Intelligibility is the legal and regulatory standard for consumer understanding, and firms need evidence that spans testing, review, revision, and outcome.
• Treat communications as part of the distribution chain, not just internal drafting. The FCA highlighted firms requesting changes to third-party communications that could mislead or confuse customers. Firms are accountable for the intelligibility of communications they do not directly write, including those from distributors, brokers, and partners.

How Amplifi supports this

Amplifi's Cognitive Risk Engine scores the intelligibility of a document instantly and identifies the specific causes of complexity across a document portfolio, not just a single readability number.

This maps directly to the FCA's findings:

• Intelligibility Risk Assessment gives firms a defined, repeatable measure of consumer understanding risk, applied consistently across all communications, including product literature, marketing communications and legal contracts.
• Content Governance embeds intelligibility standards and approved terminology into drafting, before a document reaches review.
• AI Simplification Tools flag complex sentences, ambiguous phrases, and passive voice, with AI-guided rewrites grounded in Amplifi's own intelligibility models.
• Compliance Reporting generates the audit-ready evidence trail the FCA says firms are missing: how a document was tested, what was changed, and how the consumer understanding outcome risks have reduced. 
• Upstream Assurance measures consumer understanding risk before a document reaches customers, not after. This positions Amplifi as part of a firm's assurance layer, identifying and preventing downstream outcome risks rather than responding to them once harm has occurred.

Amplifi was developed with direct FCA innovation support and has been tested through the Regulatory Sandbox since 2019. It gives firms a way to make consumer understanding a monitored, evidenced part of Consumer Duty compliance, rather than a subjective judgement made once at review.

Turning communications risk into measurable assurance for legal and regulatory compliance.

Want to see how your document portfolio scores against Consumer Duty consumer understanding requirements? Get in touch to find out more.

‍

‍