Four outcomes.
Ongoing proof.
Consumer Duty (live since July 2023) wants documented evidence, across four outcome areas, every year, per client. "We try our best" has not been a defence since the day it went live.
What the FCA expects.
Firms must demonstrate good consumer outcomes in every area, not once at onboarding, but as an ongoing evidenced practice across every client relationship.
Products & Services
Products and services must be designed for, and actually meet the needs of, a defined target market. Suitability must be demonstrated at every interaction, not assumed at onboarding. Where firms fail: the target-market statement exists in the policy doc but never gets referenced on a per-client basis.
Price & Value
Firms must evidence that charges are fair and proportionate to the value delivered. Ongoing fees must be justified by ongoing service, documented, not assumed. Where firms fail: they can show the service exists; they can't show the value delivered matched the fee charged.
Consumer Understanding
Clients must genuinely understand what they're receiving, not just sign a document. Communications must be clear, timely, and effective for the firm's specific client base. Where firms fail: the suitability letter is sent and signed; there's no record the client actually understood it.
Consumer Support
Clients must be able to access the help they need without friction or unreasonable barriers, especially vulnerable clients. Where firms fail: the support exists in principle; the firm-wide evidence that vulnerable clients actually receive it doesn't.
What compliance teams tell us
The most-repeated Consumer Duty failures across the 27 compliance officers we interviewed in 2025.
- ✕ Vulnerable client status identified but outcome documentation missing or outdated
- ✕ Fair value evidence scattered across email threads with no retrievable audit trail
- ✕ Annual Consumer Duty board report takes days to prepare, pulling data from multiple disconnected systems
- ✕ No firm-wide Consumer Duty health score; compliance officers can't see where the risk is concentrated
Amaea was built to close exactly these gaps. The four PS22/9 outcomes, tracked per client per year, with the evidence attached.
Book a demoThe Consumer Duty bits the FCA actually asks about: built in.
Four systems mapped directly to PS22/9 and FG21/1. Each one cites the specific rule on every flag it raises.
One row per client per outcome per year: products & services, price & value, consumer understanding, consumer support. Each row references the evidence document it's drawn from, so the audit trail reads as "this was assessed on this date, against this file". Not "the system says it's fine".
A nightly cron raises a re-assessment flag the day a vulnerable client crosses the 12-month FG21/1 threshold. The flag carries the client's last assessment date and the specific adaptation history, so the adviser knows what's already been done before they pick it up.
The annual board pack pulls from the same data the daily ops run against: four-outcome roll-up, vulnerable-client cohort numbers, year-on-year delta, complaints picked up that touched PS22/9. If the data isn't in the system yet, the report tells you what's missing instead of guessing.
Where ongoing fees don't match the documented ongoing service, the system raises a risk flag with the specific PS22/9 outcome reference attached. Not a generic "review needed". The flag stays open until either the service is logged or the fee arrangement is updated, both of which are written to the audit trail.