The Consumer Duty Annual Assessment: What the FCA Expects from IFA Firms in 2027
The Consumer Duty annual assessment is the part of the regime that catches firms out. Not because it is conceptually difficult, but because it asks you to produce evidence across a full year, and most IFA practices only start assembling it a few weeks before the board needs to sign it off.
By then the evidence either exists or it does not. There is no way to retrospectively prove you monitored something.
What the annual assessment actually is
Under Consumer Duty, a firm's board or equivalent governing body is expected to review annually whether the firm is delivering good outcomes for retail customers, and to document that review. It is not a form you submit. It is an internal report the FCA expects to exist and to be able to inspect.
The expectation is that the assessment is evidence based. A board minute recording that the firm believes outcomes are good, with nothing behind it, is the weakest possible position.
Where IFA firms consistently struggle
Three problems come up repeatedly, and all three are documentation problems rather than advice problems.
The evidence is scattered. Suitability reviews sit in the back office system, client communications sit in email, vulnerability notes sit in file notes, and complaints sit somewhere else entirely. Assembling them is a manual exercise every year.
Monitoring is asserted, not shown. Firms genuinely do monitor outcomes. Very few can produce a record showing what was monitored, when, and what happened as a result.
Nothing proves the negative. Demonstrating that no client was disadvantaged requires a record of having looked. Absence of complaints is not evidence of good outcomes.
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What can be evidenced automatically
Four components of the assessment can be generated from systems rather than assembled by hand.
1. Suitability review completion and timing.
A scheduled workflow that triggers each review, records when the questionnaire went out, when it came back, and when the adviser signed off, produces a complete timing record across the client base without anybody tracking it.
2. Client communication records.
Logging every outbound communication against the client record automatically gives you a searchable archive. When the assessment asks whether communications were clear and timely, you have the dates.
3. Vulnerability flags and the action taken.
Flagging is the easy part. The valuable record is what happened next: who reviewed it, what adjustment was made, and when it was revisited. That sequence can be automated end to end.
4. Management information for the board pack.
Review completion rates, average time to complete, outstanding reviews by adviser, complaint volumes and themes. Generated on a schedule, these become a standing report rather than an annual scramble.
A realistic timeline
If your assessment is due in mid 2027, the practical sequence looks like this.
Now: decide what you will need to evidence, and check which of it your systems currently capture
Within one quarter: automate the capture so the record starts accumulating
Two quarters before the assessment: produce a dry run board pack from whatever has accumulated and find the gaps while there is still time to fill them
Assessment: generate the pack from the record rather than building it
The reason to start now is simple. Evidence of continuous monitoring can only be produced by actually monitoring continuously. Starting three months before the deadline gives you three months of evidence and a nine month hole.
One caveat worth stating plainly
Automation produces the record. It does not produce the judgement. Whether an outcome was good, whether an adjustment was adequate, whether a client was genuinely understood: those remain the adviser's and the board's responsibility, and no workflow changes that.
What automation removes is the argument about whether anybody wrote it down.
Related reading
See our fuller treatment of workflow automation for IFA firms, and the five core processes worth automating first for the wider view.
Tell us what your assessment needs to show, and we will tell you which parts can write themselves.
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