Independent Financial Advisers
Consumer Duty is no longer about what you did. It is about what you can prove.
The FCA has shifted from asking whether you have implemented Consumer Duty to whether you can demonstrate with evidence that your firm is delivering good outcomes. Thirty per cent of IFA firms do not record all client conversations. The Consumer Duty Board Report is due 31 July 2026.
If your monitoring exists only in committee slides and policy PDFs, you do not have a Consumer Duty trail — you have a story.
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The regulatory landscape
IFAs operate under FCA conduct rules, SMCR accountability for Senior Managers, and Consumer Duty outcomes rules that now bite in supervision and enforcement. The FCA's advice unit and ongoing file reviews test whether suitability is evidenced — not merely asserted.
The Consumer Duty Board Report due 31 July 2026 forces a board-level account of whether good outcomes are being delivered in practice. Boards will ask compliance and advice leads for the underlying records. If those records do not exist at adviser level, the firm cannot honestly certify the report.
The Financial Ombudsman Service continues to penalise poor file-building and opaque reasoning. Ombudsman decisions are published — they become marketing and recruitment liabilities as well as financial ones.
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What regulators look for
File reviews ask whether advice reasoning is contemporaneous: why this product, for this client, at this time — with risks and costs explained in a way that matches the file, not the post-hoc complaint response.
Consumer Duty monitoring must show a pattern of active oversight: MI reviewed, outliers challenged, decisions recorded. Inspectors compare months of monitoring activity to the firm's policies — gaps become findings.
SMCR Senior Managers are asked what they personally did to deliver the Duty in their area. Generic firm responses are not personal accountability answers.
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What Evidentia gives you
Suitability decision records
Each recommendation sealed with reasoning, alternatives considered, and client-specific risk factors — the file the FCA and FOS expect to read.
Consumer Duty monitoring trail
Dated records of reviews, metrics challenged, and follow-up actions — not a policy deck.
Senior Manager reasonable-steps map
Oversight actions tied to responsibilities — so when the FCA asks what you personally did, the answer is one click away.
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The evidence gap
Most IFAs we speak to give good advice in good faith. The gap is evidentiary: conversations not logged, review promises not evidenced, monitoring described but not performed as a recorded act.
Under Consumer Duty, good faith without contemporaneous records is indistinguishable from poor practice in hindsight — that is the enforcement reality.
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Key enforcement facts
Consumer Duty Board Reports are due 31 July 2026 — evidential expectations are moving from assertion to proof.
The FCA's ongoing advice reviews have found firms charging for annual reviews that were never conducted — remediation required.
SMCR personal accountability applies to Senior Managers — firm-level policies do not answer individual enforcement questions.
Find out whether your current approach would withstand scrutiny.
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