There's no such thing as Consumer Duty software. The Duty is an outcomes standard, so no product can hold the obligation for you. What technology can do is make the evidence a by-product of the work instead of a separate exercise: consistent files, recorded reasoning, service data you didn't assemble by hand, and management information your board report can cite. The test for any tool is whether it captures evidence while the work happens, or adds another form to fill in.
Key takeaways
- No product makes a firm compliant. The obligation sits with the firm and, under SMCR, with named individuals.
- Evidence should fall out of the work. If it's an annual archaeology project, the tool has failed.
- Most firms' weak point is consistency between files, not the quality of the best file.
- Management information you assemble by hand once a year is information you can't act on.
- Ask a vendor what happens to your client data and what the tool does when it can't answer. Those 2 questions separate the serious products from the rest.
Is there such a thing as Consumer Duty software?
No. Products marketed that way usually mean 1 of 3 things: a policy pack, a questionnaire, or a dashboard fed by data you still have to enter yourself. Each can be useful, and each adds work rather than removing it.
The Consumer Duty asks for outcomes, not artefacts. A tool can help you produce good outcomes and show that you did. It can't be accountable for them. That stays with the firm, and under SMCR with the senior manager who owns it.
So the useful question isn't "is this Consumer Duty compliant". It's "does this leave a defensible trail without anyone typing one".
What does the Duty ask technology to do?
Work outcome by outcome. Each one needs different evidence, and each has a different tooling answer.
Products and services. You need a defined target market and files showing the client sat inside it. Tooling helps when segmentation lives on the client record, so a case that falls outside the target market is visible at the point of advice rather than at the annual review.
Price and value. You need an assessment of what the client gets for the fee, not the fee alone. That means knowing what service each client was promised and what they received. Tooling helps when service delivery is recorded as it happens: the review held, the pack sent, the call logged.
Consumer understanding. You need documents a client can read and a record of what was sent and when. Tooling helps with readable, consistently structured output, and with a delivery trail. It doesn't help if it produces 40 pages nobody reads faster than before.
Consumer support. You need to show it's no harder to leave, switch or complain than it was to join. Tooling helps by recording response times and chase history, which is data most firms hold and few can produce on request.
Where the evidence usually breaks
In practice, 5 failure points come up more than anything else.
- Inconsistency between files. Your best file is excellent. Your median file is fine. Your worst file was written on a Friday. The regulator's sample doesn't ask for your best one, and outcomes are judged across the book.
- Ongoing service charged but not evidenced. The review happened and nobody recorded it properly, so from the outside it looks identical to a review that never happened. This is the single most exposed area for firms with ongoing fees.
- Vulnerability recorded in the adviser's head. If a client's circumstances are known to 1 person and written nowhere, they can't shape the service, and they'll be missing from the file when it matters. Handling vulnerable clients well is a data problem as much as a training problem.
- Fair value assessed on price. Price is easy to compare and it isn't what the rule asks. The assessment needs the value side, which means the service delivered, not the service listed on the website.
- Information assembled once a year. If the board pack takes 3 weeks to build, it arrives too late to change anything and it's stale by the time it's read.
Notice that 4 of the 5 are recording problems rather than advice problems. That's why technology is relevant here at all.
The questions to ask a vendor
Take these into any demo, ours included.
- "Show me the audit trail for 1 case, end to end." Not a feature list. The actual trail: what was captured, what the system produced, who checked it, what changed, when it was sent.
- "Where does my client data go?" Which country, which sub-processors, how long it's retained, and whether it's used to train shared models. Get the answer in writing, because you need it for your own records under UK GDPR.
- "What happens when the tool can't answer?" A regulated firm needs a clear result, an honest "unavailable", or an error with a reason. A system that invents a plausible fallback is worse than a system that stops, because a wrong number reaches the client with your name on it.
- "Which step can't be skipped?" There should be a human sign-off that isn't optional and is recorded. If a document can leave the firm without one, the control doesn't exist.
- "Can I export everything?" Your files, in a usable format, whenever you want, including after you leave.
- "Does the management information come from the work, or from a form?" Data that someone has to remember to enter is data you won't have when you need it.
Nobody holds a certification for "Consumer Duty ready", so ignore any badge implying otherwise and judge the trail instead.
What technology can't do
It can't set your target market, decide your fees are fair, or write the honest paragraph in the board report that says a service isn't landing. It can show you that reviews are slipping. Deciding to stop selling that service, or to fix it, is governance, and governance doesn't come in a subscription.
It also can't make a rushed file safe. Producing drafts faster than a qualified person can properly check them isn't compliance capacity, it's a queue of unchecked work with your sign-off on the end of it.
Frequently asked questions
Is there software that makes a firm Consumer Duty compliant?
No. The Duty is an outcomes standard applying to the firm, and no vendor can take that on. What good software does is capture the evidence while the work happens, so files are consistent, service delivery is recorded, and your management information is a query rather than a project. Treat any product claiming compliance itself as a warning sign.
What management information does the FCA expect for the Consumer Duty?
The regulator expects information that lets your governing body judge whether customers are getting good outcomes, and act when they aren't. In practice that means data on service delivery against what was promised, outcomes across client segments including vulnerable clients, complaints and their root causes, and price and value evidence. The FCA's finalised guidance is explicit that firms should be able to show the results customers get, not only that a process was followed.
Can AI write the Consumer Duty board report?
It can assemble the data and produce a first draft, and that removes real work. It can't do the part that matters, which is the honest judgement about what the data shows and what the firm will change. A board report drafted by a tool and signed without challenge is a governance failure with better formatting.
How do you evidence fair value for ongoing advice?
Record what each client was promised, record what they received, and compare the 2 across the book rather than case by case. That means dated evidence of reviews held, documents issued and contact made, held against the fee charged. If you can't produce that comparison on demand for a whole segment, the assessment is an assertion rather than an assessment.
What's the fastest Consumer Duty improvement for a small firm?
Make service delivery a recorded event instead of a memory. Every review, pack and material contact logged against the client, in 1 place, at the time. It costs nothing beyond discipline, it fixes the most exposed evidence gap for firms with ongoing fees, and it turns the annual assessment into a report you run rather than a fortnight you lose.