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Consumer Duty MI: What Should Firms Actually Measure?

Consumer Duty has changed the conversation around compliance.

It’s no longer enough for firms to simply have policies, procedures and file checks in place. The FCA expects firms to demonstrate that they are consistently delivering good outcomes for customers—and that means having meaningful Management Information (MI).

For many mortgage and non-investment insurance firms, that’s where the uncertainty begins.

Should you be tracking complaints? File review scores? Vulnerable customers? Adviser performance? Customer feedback? Everything?

The short answer is no.

Good Consumer Duty MI isn’t about measuring everything you possibly can. It’s about collecting the right information, understanding what it tells you, and using it to improve customer outcomes.

In this guide, we’ll explain what effective Consumer Duty MI looks like, the types of data firms should consider monitoring, and the common mistakes that can leave firms with lots of reports—but very little insight.

What This Article Covers

In this guide, we’ll look at:

  • What Consumer Duty Management Information (MI) actually is.
  • Why MI is so important under the FCA’s Consumer Duty.
  • The key areas mortgage and protection firms should be monitoring.
  • Examples of meaningful MI for advisers, customers and business performance.
  • Common mistakes firms make when collecting MI.
  • How to use MI to evidence good customer outcomes.

What Is Consumer Duty MI?

Management Information (MI) is simply the data your firm collects and reviews to understand how well your business is performing.

Under Consumer Duty, that data should answer one key question:

“Are our customers consistently receiving good outcomes?”

If your MI can’t answer that question, it probably isn’t telling you what you really need to know.

The FCA doesn’t prescribe a standard set of reports or KPIs. Instead, firms are expected to develop MI that reflects the size, nature and complexity of their business.

That flexibility is helpful—but it also means firms need to think carefully about what they measure.

Why Is MI So Important?

Consumer Duty has shifted compliance away from simply proving you’ve followed a process.

Instead, firms must understand whether those processes are actually working.

For example, completing monthly file reviews is useful—but what are those reviews telling you?

  • Are advisers making the same mistakes repeatedly?
  • Are vulnerable customers receiving additional support?
  • Are complaints increasing?
  • Are recommendations delivering suitable outcomes?

Without meaningful MI, those trends can easily go unnoticed.

Good MI helps firms identify issues early, make informed decisions and demonstrate to the FCA that they are actively monitoring customer outcomes.

What Should Mortgage and Protection Firms Measure?

Every business will be different, but there are several areas that most firms should consider including within their Consumer Duty MI.

1. File Review Results

Compliance file checking remains one of the most valuable sources of management information.

Rather than simply recording pass or fail results, firms should analyse:

  • Overall file quality.
  • Common compliance findings.
  • Suitability report issues.
  • Repeat adviser errors.
  • Trends over time.
  • Improvements following training.

The objective isn’t to catch advisers out—it’s to identify where improvements are needed.

2. Customer Complaints

Complaints provide valuable insight into customer outcomes.

Useful MI includes:

  • Number of complaints.
  • Complaint categories.
  • Root causes.
  • Complaint outcomes.
  • Resolution times.
  • Trends by adviser or business area.

Even firms with very few complaints should review them carefully, as a single complaint can highlight wider issues.

3. Vulnerable Customers

Consumer Duty places significant emphasis on identifying and supporting vulnerable customers.

Your MI may include:

  • Number of vulnerable customers identified.
  • Types of vulnerability.
  • Additional support provided.
  • Products recommended.
  • Customer outcomes.
  • Any trends requiring further investigation.

Monitoring this data helps demonstrate that vulnerable customers receive outcomes comparable to other clients.

4. Adviser Performance

Consumer Duty isn’t about league tables—it is about identifying where advisers may need additional support.

Examples of useful MI include:

  • File review scores.
  • Observation results.
  • Competency assessments.
  • CPD completion.
  • Training outcomes.
  • Repeat compliance findings.

Patterns are often more valuable than individual results.

5. Customer Feedback

Customer feedback provides another important measure of good outcomes.

Consider monitoring:

  • Customer surveys.
  • Net Promoter Score (where applicable).
  • Google Reviews.
  • Referral rates.
  • Repeat business.
  • Customer satisfaction trends.

Positive feedback should support—not replace—other compliance monitoring.

6. Product and Recommendation Trends

Consumer Duty expects firms to understand the products they recommend.

Examples of useful MI include:

  • Lender distribution.
  • Protection provider distribution.
  • Mortgage decline rates.
  • Policy lapse rates.
  • Customer cancellations.
  • Cases that do not proceed.
  • Fee refunds.

Unexpected trends may indicate that recommendations, processes or customer understanding need reviewing.

Common Consumer Duty MI Mistakes

One of the biggest mistakes we see is firms collecting data simply because they think they should.

This often leads to lengthy spreadsheets packed with statistics that nobody reviews.

Common mistakes include:

  • Measuring too many KPIs.
  • Collecting data without analysing it.
  • Reviewing MI only once a year.
  • Failing to investigate trends.
  • Not recording actions taken.
  • Focusing purely on compliance rather than customer outcomes.

Remember—MI only becomes valuable when it leads to action.

Turning Data Into Better Outcomes

The FCA wants firms to use MI as a management tool—not just a compliance exercise.

Every review of your MI should prompt questions such as:

  • What is this data telling us?
  • Are customers achieving consistently good outcomes?
  • Have we identified any emerging risks?
  • Do advisers require additional support?
  • Have previous actions improved performance?

If the answer is yes, your MI is doing exactly what Consumer Duty intended.

Final Thoughts

Consumer Duty MI isn’t about producing more reports.

It’s about understanding your business, identifying risks early, and continually improving customer outcomes.

For mortgage and non-investment insurance firms, meaningful MI provides confidence that your compliance framework is working—and evidence that you are meeting the FCA’s expectations.

Rather than measuring everything, focus on the information that genuinely helps you answer one simple question:

“How do we know our customers are receiving good outcomes?”

If your current reporting doesn’t provide that answer, it’s probably time to review your MI framework.

How H3 Consultancy Can Help

At H3 Consultancy, we work with FCA-regulated mortgage and non-investment insurance firms to develop practical Consumer Duty frameworks that go beyond ticking compliance boxes.

Whether you need support reviewing your Management Information, strengthening your compliance monitoring programme or improving the quality of your file reviews, our experienced consultants can help you build a framework that demonstrates good customer outcomes and stands up to FCA scrutiny.

Want to review your Consumer Duty MI? Get in touch with the H3 Consultancy team to discuss how we can support your business.that your advice stands up to scrutiny.ing one of the most important decisions in the adviser journey—awarding Competent Adviser Status.

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