Consumer Duty is a proof problem. Proven Duty is the evidence layer: it scores what your firm already produces and makes the evidence exist.
You already write suitability reports, keep client files, and run reviews. Proven Duty turns that existing output into structured, board-ready evidence — file by file, against a fixed rubric derived from FCA guidance (COBS, PROD, PRIN 2A).
The rubric is drawn from the FCA's Consumer Duty expectations — COBS 9 suitability checks, the PRIN 2A outcomes, FG21/1 vulnerability — and versioned, so the firm always knows exactly what it was scored against in any given quarter. The point is that the input already exists: nothing about running Consumer Duty well requires a new way of working, only a record of the way of working you already have.
Every check returns a result with the reason attached — so a reviewer can agree or overrule it, and the file shows why. The flags are line-referenced back to the report.
| Check | Result | What the reviewer sees |
|---|---|---|
| ObjectivesReport §2 | PASS | Rationale quotes the client's objective in their own words |
| VulnerabilityReport §4 | PASS | Considered and documented; no indicators identified, reason given |
| ChargesReport §6, p.3 | AMBER | Ongoing charge stated, but impact on returns not shown |
| AlternativesReport §7 | FAIL | Alternatives named without the reason they were discounted |
| Capacity for lossReport §5 | PASS | Loss impact addressed against stated circumstances |
| Ongoing serviceReport §9 | AMBER | Review promised, but no next review date |
The Consumer Duty requires firms to act to deliver good outcomes for retail customers across four outcome areas — products and services, price and value, consumer understanding, and consumer support — and to be able to demonstrate those outcomes. The FCA's Consumer Duty pages set the expectation out in plain terms: the firm's monitoring and its board reporting are part of the duty, not an add-on.
The FCA keeps narrowing what “evidence” means in practice. Its Consumer Duty focus areas and requirements review — in the Consumer Duty publications library — make outcomes monitoring and the annual assessment standing priorities, and its Enforcement Watch series spells out the consequences for firms that cannot show it. Against that backdrop, the firms the FCA's financial advice market data describes — thousands of directly authorised firms, most of them small — are expected to maintain evidence machinery that looks like it was built for firms ten times their size.
In practical terms the expectation is a cycle, not a pile of documents: score the files, log the results, review the patterns across the client bank, and report to the board. The cycle runs on whatever the firm judges proportionate and repeats every year — quarterly for the management information, annually for the full assessment. The evidence has to be consistent enough that a reviewer can see the same checks applied to every file and the same cycle turning each year.
That gap between the expectation and the machinery is what Proven Duty exists to close: the evidence layer a small firm can actually run, without a compliance department behind it.
From £49 per adviser per month. No retainer, no implementation project. Your first report can be scored in hours, not weeks.
Compare with a day of consultant time on a file-review project — and the review only happens once. Proven Duty makes every file a review.
Every file review returns an overall grade (Pass / Amber / Fail), line-level flags, and the rule behind each flag. The scorecard is the same outcome-evidence format the FCA's outcomes monitoring asks to see.
The file before scoring
A suitability report with a strong recommendation but a thin record: percentages without a total cost in pounds, no named alternatives, no service log for the ongoing charge, and no vulnerability consideration on file.
The same file after scoring
Overall Amber. Line-level flags: cost disclosure (total cost missing), alternatives (none recorded), ongoing service (log empty). Each flag cites the rule and the exact paragraph of the report where the evidence should sit — ready for the adviser to respond or dismiss.
The flag rules map to the checks the FCA expects to see evidenced: suitability reasoning and cost disclosure from COBS 9, vulnerability consideration from FG21/1, value for money and ongoing service from PRIN 2A. The rubric is versioned, so a score from last year can be compared honestly with one from this year, and every override — where an adviser changed a score and wrote why — sits in the audit trail next to it.
Nothing is auto-approved. Flags are the starting point of a human decision — the adviser reviews, edits, and signs off every one. The audit trail keeps the whole conversation: who reviewed, when, and what they decided.
Three common ways firms try to evidence Consumer Duty, and where each leaves the firm:
| Dimension | Manual reviews | Consultant day | Proven Duty |
|---|---|---|---|
| Coverage | A sample, then the rest assumed | A handful of files, once | Every file, every time |
| Record | Notes, if kept | A report, then nothing | Graded, timestamped, signed off |
| Board pack | Built in a spreadsheet | One-off deliverable | Generated from the review log |
| Cost | Adviser hours every quarter | A project price each time | From £49 per adviser per month |
The distinction that matters is what exists after the day is over. A consultant review produces a report; a manual review produces findings. Proven Duty produces the evidence chain — the log, the trend, the board summary — that keeps working every quarter.
That is also why the record matters more than the tool. Whatever method a firm uses, a reviewer reads the file cold and asks the same three questions: what did you check, what did you find, and what did you do about it. The evidence layer is simply the place where those three answers live — complete, consistent, and dated.
Consultants advise; Proven Duty produces evidence. A day of consultant time reviews a handful of files once. Proven Duty scores every file you produce against a fixed rubric, logs the results, and builds the board report from them — the consultant channel has been a strength of the firm's approach, and many firms use both.
No. Every AI assessment requires human sign-off. Proven Duty flags issues and produces structured evidence — the adviser reviews, edits, and approves. This is a tool, not an auto-approver. Human oversight is built into every workflow.
No, and we are careful to say so. No tool can promise a regulatory outcome — the FCA's expectations are about what your firm does and can evidence. Proven Duty's job is to make the evidence exist: it flags, you judge. The rubric is versioned and auditable, so your reviewers can see exactly what was checked and why.
The duty asks firms to monitor the outcomes customers receive across four areas — products and services, price and value, consumer understanding, and consumer support — and to be able to show good outcomes. The FCA's Consumer Duty pages and its publications library set out the expectations, and its focus areas keep outcomes monitoring and the annual assessment in scope.
On UK/EU-hosted infrastructure with row-level security. Your firm's data is isolated from every other firm, encrypted at rest and in transit, and processed under a data processing agreement. Full GDPR compliance is part of the service, not an add-on.
Yes, and many firms do. Proven Duty handles the evidence-gathering part of the cycle — file reviews, vulnerability flags, outcomes reporting — and produces the raw material your consultant would otherwise build by hand. Your consultant keeps the strategic layer; the evidence layer stops being the bottleneck in the conversation.
Every score is a flag, not a final judgement. The adviser reviews each assessment, can edit or dismiss a flag, and explicitly approves the outcome. Errors surface in the human review step — that is how the workflow is designed — and the override log is part of the audit trail, not something hidden from it.
Upload an anonymised suitability report and see the scorecard — every check scored, every flag line-referenced, the rule behind it, and the paragraph where the evidence should sit. Human review before, during, and after.