Consumer Duty Outcomes Monitoring: How the FCA Is Testing Payment Firms in 2026

The Consumer Duty has moved beyond implementation. In 2026, the FCA is actively testing whether payment firms are delivering the good outcomes that the Duty requires. This article examines the FCA's approach to outcomes monitoring, the data it is collecting, common compliance gaps identified in payment firms, and how to prepare for supervisory review.

The FCA's Outcomes Testing Approach

The FCA has been clear that Consumer Duty compliance is not about having policies and procedures in place — it is about demonstrating that those policies deliver good outcomes for customers in practice. The regulator is using multiple supervisory tools to assess outcomes:

Data-driven analysis. The FCA is collecting and analysing data on complaint volumes, complaint resolution times, customer attrition rates, fee structures, and customer journey completion rates. Payment firms should expect targeted data requests under Section 165 of FSMA.

Multi-firm reviews. The FCA is conducting thematic reviews across the payments sector, examining how firms approach fair value assessment, customer communications and complaints handling.

Mystery shopping. The FCA is using mystery shopping exercises to test the real customer experience — including the quality of customer support, the clarity of fee disclosures, and the ease of complaint submission.

The Four Outcome Areas for Payment Firms

Products and services. Payment products and services must be designed to meet the needs of the target market. The FCA expects firms to conduct regular product reviews, assessing whether products continue to meet customer needs and whether any features cause foreseeable harm.

Fair value. The total price paid by customers — including fees, charges, exchange rate margins and any other costs — must be proportionate to the benefits the product delivers. For payment institutions, this means scrutinising FX margins on international transfers, transaction fees, account maintenance charges and any penalty fees.

Customer understanding. Communications must enable customers to make informed decisions. For payment firms, this includes clear disclosure of fees before transaction completion, transparent exchange rates, and plain-language terms and conditions.

Customer support. Support must be accessible, responsive and effective. The FCA is monitoring average complaint resolution times, the availability of support channels (phone, email, chat), and customer satisfaction indicators.

Common Compliance Gaps in Payment Firms

The FCA has identified several recurring issues in payment firms:

1. Superficial fair value assessments. Firms that compare their pricing to competitors without analysing whether the total cost is proportionate to the benefits delivered.
2. Inadequate monitoring frameworks. Firms that have no systematic process for collecting and analysing customer outcome data.
3. Reactive complaints handling. Firms that address individual complaints without analysing root causes or taking systemic corrective action.
4. Opaque fee structures. Firms where the true cost of a transaction is not clearly disclosed before the customer commits.
5. Digital-only support. Firms that offer no alternative support channels for customers unable to use digital platforms.

Building an Effective Outcomes Monitoring Framework

An effective Consumer Duty outcomes monitoring framework for payment firms should include:

• Regular data collection on key outcome indicators (complaint volumes, resolution times, NPS scores, fee income analysis by customer segment)
• Quarterly board-level reporting on Customer Duty outcomes with trend analysis
• Annual product reviews assessing whether products continue to meet target market needs
• Fair value assessments updated annually or following material changes to pricing
• Root cause analysis for complaint themes, with evidence of corrective action
• Customer journey testing to verify that communications are clear and not misleading

What Firms Should Do Now

1. Review your Consumer Duty monitoring framework — is it collecting the right data and reporting to the board at the right frequency?
2. Conduct a fair value assessment across all products and services, documenting the methodology and conclusions.
3. Analyse complaint data for themes and root causes — implement corrective action where patterns emerge.
4. Test your customer journey from onboarding to transaction completion — is the fee disclosure clear and timely?
5. Prepare for FCA data requests by ensuring your systems can extract customer outcome data efficiently.

Regulatory Counsel advises payment firms on Consumer Duty compliance, outcomes monitoring frameworks and fair value assessments. Contact us for a free initial consultation.