The Consumer Duty annual board report for a small advice firm: what PRIN 2A.8.3 requires, what the FCA found in the first ones, and a shape for a firm of three to ten people

"Consumer duty report template" is typed every July. The rule does not ask for a template. PRIN 2A.8.3 asks the firm to prepare a report for its governing body setting out the results of its outcomes monitoring and any actions required, and PRIN 2A.8.4 asks the governing body to review and approve it at least annually, to confirm whether it is satisfied the firm is complying with the Duty, and to assess whether the firm's strategy is consistent with it. For a firm of three to ten people the governing body is the directors, and the report is the evidence that they looked.

When

Annually. The first reports were due by 31 July 2024, a year after the Duty came into force for open products, and most firms have kept 31 July as their cycle. The FCA does not set the date; the firm's own policy does, and a report produced on the same date each year is itself evidence of a process.

What the FCA found in the first ones

The FCA reviewed a sample of first-year reports and published good practice and areas for improvement in December 2024, updating it in February 2026 with findings on how smaller firms can meet the requirement proportionately. It found good practice in firms of all sizes, including those with fewer than ten employees. The weaknesses it named were reports that described processes rather than outcomes, that lacked data, that did not say what the firm had done about what it found, and that did not show the board challenging the findings.

The lesson for a small firm is the opposite of what the templates suggest. Shorter, with numbers, with actions, with a record of the directors' questions.

A shape for a small firm

Six sections, each a page or less.

1. What we monitored. The four outcomes (products and services, price and value, consumer understanding, consumer support) and the measures used for each: review delivery rates, complaint numbers and themes, fee levels against service, report readability, response times to clients, vulnerable client numbers and how they were served.
2. What the numbers say. The actual figures for the year against last year. The ongoing service tracker gives the delivery figures; the complaints log gives the complaints; the charging schedule and the charging illustration give the price and value evidence.
3. Where we fell short. Named, with the client groups affected and what it cost them.
4. What we did and will do. Actions with owners and dates. The FCA's complaint about the first reports was the absence of this section.
5. Vulnerability. How vulnerable clients were identified, how many, and whether their outcomes differed.
6. The directors' conclusion. Whether they are satisfied the firm is complying, what they challenged, and whether the strategy for the coming year is consistent with the Duty. Signed and dated.

The data problem

Most small firms have the data and have never put it in one place. Review delivery lives in the back office as tasks, complaints in a spreadsheet, fees in the charging schedule, vulnerability in client notes. The report is mostly the work of pulling those into a table once a year, and the firm that does it monthly finds the July report takes an afternoon.

What it is not

It is not sent to the FCA unless asked for; it is held and produced on request, and it is the first document an FCA supervision visit or a buyer's due diligence asks for. It is not a policy document; the firm's Consumer Duty policy is separate and is referred to. And it is not marketing: a report that finds nothing wrong in a year is read as a report that did not look.

In the firm

An AI Review Coordinator and File Checker set up by Overlyft produce the numbers: review delivery by client and year, file check pass rates, complaints logged with themes, chase and response times, from the firm's own systems each month, so the July report is assembled rather than researched. The directors write the conclusion and the compliance function reviews the whole. Nothing here is a judgement on the firm's compliance; that is the directors'. General information from the Handbook and the FCA's published findings; not regulatory advice.