Consumer Duty in Banking: Evidence of Good Customer Outcomes
Consumer Duty compliance requires banks to act to deliver good outcomes, not simply show that processes followed written procedures. Evidence should cover products and services, price and value, consumer understanding and support.
Regulatory and risk context
Product governance should define target markets, needs, foreseeable harm, distribution, value and review triggers. Communication testing must assess whether customers understand important features and risks, including vulnerable customers and digital journeys.
Implementation architecture
Outcome monitoring should combine complaints, arrears, cancellations, fees, service friction, declined support, digital abandonment and qualitative review. Segment results because acceptable averages can hide poor outcomes for a smaller cohort.
Where programmes fail
Weak programmes rely on customer satisfaction, policy compliance or low complaint numbers as proof. Customers may not recognise harm or may abandon a difficult process without complaining. Remediation should address root cause, not only individual redress.
Board and senior-management evidence
The governing body should approve the outcomes report, challenge strategy and agree action where customers do not receive good outcomes. Reporting should show affected populations, causes, owners and verified closure.
Five-step control checklist
- Define the legal and regulatory scope.
- Assign accountable business and compliance owners.
- Map obligations to data, systems, procedures and evidence.
- Test design and operating effectiveness.
- Escalate limitations and verify remediation.
Primary regulatory references
Related banking-compliance articles
- EU AML Package and AMLA: A Bank Readiness Framework
- AML Customer Risk Assessment for Banks: From Score to Decision
- Transaction Monitoring Effectiveness: Beyond Alert Volumes
- Sanctions Screening Governance for Banks in a Fast-Changing Environment
About the author
Jonas Adam Mohamed Osman, known as Yonas Osman, writes evidence-led analysis on banking risk, compliance, quantitative finance and governance.