How to evidence your file-review methodology in one page
“Show me your methodology” is the first question an FCA reviewer asks. One page, three sections, answers it.
What the FCA says about how firms review files
The Consumer Duty requires a firm to monitor and review the outcomes its clients receive. The FCA's Consumer Duty pages set out the monitoring expectation in each outcome area — which is why “show me your methodology” is a routine opening question.
The Consumer Duty publications library carries the FCA's guidance on file reviews and outcomes, including good and poor practice. A firm that can evidence its methodology enters that conversation ahead of one that cannot.
The methodology page, three sections
Scope, grading and governance answer what was reviewed, how it was scored, and who is accountable.
Scope
What the methodology covers: the review types, the client segments, the frequency, and the sample if any. Explicit about what is in scope.
Grading
The fixed rubric — the check areas, the Pass / Amber / Fail bands, and how a score is assigned. The same test every time.
Governance
Who reviews, who signs off, how overrides are recorded, and how results feed the board report. The audit trail that makes it real.
The methodology page is not a marketing document. It is the record a reviewer can hold against your actual reviews — and it either matches them or it does not.
Worked example: a methodology that answers “show me”
The test: can a reviewer take the page and trace any review in your file against it?
Before
“We review client files against the Consumer Duty and escalate anything material.” A paragraph of intent, with no scope, no rubric, no frequency, and no record that any of it happened.
After
“Scope: every ongoing-client file, reviewed on a three-year cycle, plus all files at recommendation or review triggers. Grading: the twelve check areas, scored Pass / Amber / Fail against a fixed rubric (v1.4), each line-referenced. Governance: named reviewer and approver, overrides logged, quarterly summary to the board minuted.” Every claim maps to a record that exists.
Common mistakes in methodology evidence
- Stating intent instead of an evidence trail. “We take file review seriously” cannot be verified. “The last 32 reviews are dated and scored” can.
- A methodology that is not the practice. A three-year cycle on the page with annual reviews in the file is a mismatch a reviewer finds quickly.
- No calibration. If two reviewers score the same file differently, the rubric is not fixed. Calibration sessions, with results recorded, are part of the evidence.
- No governance escalation. Findings that are never screened, actioned or escalated are findings that never happened for the purposes of the methodology.
What each part of the page must contain
| Element | What it must contain | The evidence it produces |
|---|---|---|
| Scope | Review types, client segments, frequency and sample. | A review calendar that can be checked against the file list. |
| Grading | The check areas, the bands, and how a score is assigned. | A rubric version that matches the scored reviews. |
| Governance | Who reviews, who approves, how overrides are logged. | A sign-off trail for every review and escalation. |
| Calibration | How scoring consistency is tested over time. | Recorded calibration sessions and their outcomes. |
Related reads
The methodology exists so the reviews are evidence. See the file review and suitability hub for the full picture, the suitability expectations for the report the reviews score against, and the 12-point file-review checklist for the rubric, review-ready.
Frequently asked questions
Does the FCA require a written methodology?
The Consumer Duty requires firms to monitor and review outcomes, and a reviewer will ask how. A written methodology — scope, grading, governance — shows it is a designed process, not an activity that varies by reviewer.
How long does the methodology page need to be?
One page for the reviewer in the first meeting: what is reviewed, how it is scored, who signs off, and what happens to the findings. The detail lives in the underlying records.
What if the reviews do not match the methodology?
That gap is the risk, not the paperwork. Either the methodology describes what happens, or the reviews become the methodology — they have to match.
Your next step
Draft the page this week: scope, grading and governance, each with a record behind it. Proven Duty provides the rubric, scoring and sign-off trail it needs. See pricing or talk to us.
Before a reviewer asks: score your evidence in 4 minutes — no email needed for the grade.