From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice - Webinar Summary | From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice

From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice

Webinar Summary: Key video highlights and takeaways from our webinar with Square 4 on Thursday 9 April 2026.

Webinar Summary: Key video highlights and takeaways from our webinar with Square 4 on Thursday 9 April 2026.Contents

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Session Summary

On Thursday 9 April 2026, we were joined by Matthew Drage, Director and Co-Founder of ICA Compliance Consultancy Firm of the Year award winners, Square 4, to discuss how and why firms need to bring together the two disciplines of employee competence and outcome testing.

With 470 senior financial services professionals from cross-sector firms in attendance, our discussion and poll engagement with participants raised key considerations for firms to consider.

In poll one, we asked firms: ‘If the FCA called tomorrow and asked for evidence, what would firms reach for first?’ Whilst 33% said they would have ‘good outcomes evidence that could show the FCA a clear picture of outcomes’, 67% said they would be demonstrating ‘activity-based evidence’ in the main, which wouldn’t tell the whole story.

In poll two, we asked firms to select two descriptions which best describes the state of their Management Information currently. 30% said they were ‘in good shape’, yet the majority of firms candidly said they have ‘data but not conclusions’ (41%), they ‘track activity, not outcomes’ (35%), they can ‘identify issues but can’t show how they are fixed’ (24%), and ‘MI lacks thresholds and rationale’ (20%).

Poll three results revealed that just 6% of firms systematically link staff learning and competence with outcome testing. Most firms (58%) say the two disciplines are partially connected, but it’s not consistent. 26% stated the two disciplines run independently of each other, whilst 9% were ‘not sure how connected they are’.

Poll result three is particularly important for firms to consider, as Matthew Drage cited that the primary failures Square 4 see when they conduct outcome testing in firms are colleague failures and their ability to adequately support customers to get the right outcome during interactions. Matthew noted that this challenge was down to colleagues going through initial training but simply not remaining competent over time.

Key highlights in this video workbook include:

The challenges of relying on activity-based evidence.
Common themes running through recent FCA publications.
Using continual assessment models to improve employee competence.
Why executive teams should embrace uncomfortable data.

1.

“All too often, we are seeing activity-based evidence that has been rebadged.”

"We have some firms that have progressed towards really good, measurable, and defined outcome statements. They have mapped the customer journey, they can demonstrate good outcomes across that journey, and that is feeding into the board report.

But all too often, we are seeing activity-based evidence that has been rebadged – QA on steroids, rebadged activity-based evidence that is going into board reports – and that is not really going to cut it."

2.

“What are the cross-cutting messages from recent FCA publications?”

"I think what comes across loud and clear in those publications is that Consumer Duty is now about evidence; it is not about intent anymore. You need to prove those outcomes with data, and you need to have robust outcomes monitoring.

The days of activity-based evidence, unfortunately, should no longer be there. If they are there, that is okay – it can be supplemental – but it should not be primary."

3.

“Activity-based evidence vs outcomes-based evidence: What’s the difference?”

"Activity-based evidence is all around looking at inputs and actions, but not actually looking at whether they have worked.

Where outcomes are different is that it does not just test that that activity has taken place. It does not just test that the process has worked or what has happened; it completes that feedback cycle."

4.

“Activity-based evidence: In the context of your staff training and competence.”

"Activity-based evidence, in the context of your employees and training, would be: “I have trained all of my staff.

So, a thousand colleagues have all been trained. Here is the evidence that they have been trained between the 1st of January and the 31st. There we go – everyone has been trained. Everyone has taken the test at the end of it, and everyone has passed."

5.

“Intelligent competency management of your business.”

"The fact that the average competence of your employees in, for example, your claims function is 78% is not a reason to throw oneself under the bus, especially if it was 58% when you started the process last year.

It shows material good governance, control, and management of the business to improve over time. If I was a regulator looking at that, I’d say that is mature, intelligent management of the business."

6.

“Employee competence under Consumer Duty: Firms are measuring the wrong data point.”

"In the absence of any policies or procedures, a competent employee can still deliver a good customer outcome. In the event of a good policy and procedure, an incompetent employee cannot necessarily deliver a good outcome.

So, the competence component is critical, and most employers would fail to credibly quantify employee competence."

7.

“Outcomes testing under Consumer Duty: The primary failure we still see is colleague failure.”

"The primary failure we do still see is colleague failures, and that is where something has gone wrong. The colleague has gone through the training – he or she has gone through the training, they have completed it, and they have passed it – but actually, they just have not remained competent.

They have not taken that on board. They have not been able to support the end customer in that particular situation, challenging as it may be."

8.

“Exec mindset change: Train for employee competence.”

"I think what firms need to do is undergo a mindset shift. Particularly the executives – I mean, I’ve led big businesses; they have to take the weight of command. They need to change their perspective and their demands.

They should not expect to see a “sea of green” as far as their employees are concerned. They need to press reset and say, “I am prepared to accept an honest appraisal of the competence of our employees, even if it is in conflict with my previous view that everything was okay."

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