Consumer Duty in 2026: the audit trail you should already have
A practical sketch of what Consumer Duty actually requires from a recommendation, and the small number of artefacts that prove it. No theatre, no acronyms.
Consumer Duty is a practical regulation written in regulator-prose. The practical bit is straightforward; the prose is what makes firms anxious. This post is a sketch of the artefacts a sensible firm should be producing per case, and where the gaps usually are.
The four outcomes, in plain English
- Products and services. The recommended product fits the client's needs and circumstances.
- Price and value. The product is fair value for the client's situation.
- Consumer understanding. The client understands what they are getting and what it costs.
- Consumer support. The firm is reachable when the client needs help.
For a regulated mortgage adviser, a defensible recommendation file should produce evidence on each of these four - and the file should be retrievable years later without anyone having to remember anything.
What each artefact actually is
For "products and services", you need a record showing the recommended product was matched against the client's stated needs (term, repayment type, fixed vs variable, life-event horizons) and the panel was filtered against criteria the client meets. That is criteria-matching plus rationale, dated.
For "price and value", the rate itself plus a side-by-side comparison with two or three alternates and a one-line "why this not those" note. Total cost over the initial rate period, not just headline rate.
For "consumer understanding", the IDD/KFI, the client's signed acknowledgement, and any recorded explanation calls. Plus, ideally, a copy of the simplified summary you walked them through.
For "consumer support", the firm's documented response-time policy plus actual response times in your case-handling logs.
Where firms typically fall short
The "panel was filtered against criteria the client meets" bit is where most files have gaps. Brokers source the rate, justify the rate, but do not produce a defensible record of the criteria filtering. If a client later complains they were sold a product they could not actually qualify for at a different lender, the file does not show why those alternatives were ruled out.
Criteria-matching is the missing artefact in a lot of files we have audited.
How BrokerBricks helps
Build a case in Criteria and you see which lenders fit, which decline and the published policy behind each answer. Save the case and you can reopen it later.
We are not going to pretend it solves the regulation. But it removes a class of busy-work, and it makes the most common audit gap easier to close.
