Consumer Duty isn't a tick-box. So why treat it like one?
The FCA wants evidence of outcomes, we do that.
The compliance illusion
Consumer Duty raised the bar. The FCA now expects firms to demonstrate — with evidence — that they are delivering good outcomes for clients. Not just at the point of sale, but continuously.
Most firms responded by adding more file checks. More checklists. More manual reviews. The irony is thick: the regulation designed to focus firms on outcomes has, in many cases, just created more paperwork about process.
Here is the problem with manual file checks. They are expensive — a typical file review costs between £150 and £300. They are retrospective — you find the problem weeks or months after the advice was given. And they are sample-based, you check 5-10% of files and hope the rest are fine.
The FCA does not want to see that you checked 8% of your files last quarter. They want to see that 100% of your clients received suitable advice, were engaged meaningfully, and that you intervened when circumstances changed. That requires structured data, not bigger filing cabinets.
Every month you rely on manual compliance processes, you accumulate risk you cannot see and cannot quantify.
Compliance built in, not bolted on
Focus does not add a compliance layer on top of your advice process. Compliance is the advice process.
Every step in a Focus workflow produces structured, auditable data. When an adviser makes a recommendation, the system captures the rationale, the alternatives considered, the risk assessment, and the client's response, not as free text in a file note, but as structured fields that can be queried, reported and evidenced at scale.
This means you can demonstrate suitability across your entire book, not just the files you happened to review. You can identify patterns — where advice is consistently strong, where it needs attention — before the FCA asks.
Automated audit trails capture every data change, every client interaction, every system event. Any change can trigger a task or workflow, so your compliance team gets real-time visibility rather than retrospective sample checks.
The firms using Focus for Consumer Duty evidence spend less time on compliance and produce better evidence. That is not a contradiction; it is what happens when you replace manual processes with structured automation.
AI compliance, where it helps
A machine line of defence
Structured data gets you the evidence; AI gets you the coverage. We partner with Aveni, whose AI-driven compliance solution acts as a "Machine Line of Defence" — systematically analysing every call and document to run suitability checks, risk assessments and audit trails at scale.
Instead of sampling 5–10% of files and hoping, you move toward 100% oversight: real-time Consumer Duty monitoring, cases prioritised for review, vulnerable customers flagged, and regulator-ready reporting — with the deterministic Focus engines doing the advice underneath.
Consumer Duty evidence, how Focus delivers
CONSUMER DUTY AT SCALE
Evidence the FCA can read, not files you have to defend
100%
Cases evidenced, every recommendation, every rationale, every alternative considered
0
Manual file notes required to demonstrate suitability
Real-time
Compliance flags before advice is delivered, not months after
8%
Of files reviewed by a typical manual QA cycle (we replace this)
£150–300
Per file under the manual model, gone with structured automation
14 yrs
Live with NFU Mutual, Consumer Duty evidence at enterprise scale
Tools for Consumer Duty compliance
Consumer Duty evidence is not a single product — it is the output of an advice process that captures structured data at every step.
Advice Engine — Deterministic suitability assessments with full audit trails. Every recommendation is evidenced, every alternative is recorded, every rationale is structured.
Advice Management — Workflow automation that ensures every case follows your defined process. No steps skipped, no evidence gaps, no reliance on individual adviser discipline.
Together, these tools mean your Consumer Duty evidence is a byproduct of doing your job, not an additional task bolted onto it.
Stop building compliance evidence manually.
Talk to us about how Focus makes Consumer Duty evidence a byproduct of good advice, not a separate workstream.