It is judged on outcomes, not process
The Duty raised the standard from treating customers fairly to delivering good outcomes and avoiding foreseeable harm. You are assessed on what actually happened to the client, evidenced across every piece of advice, not a sample gathered once a year.
Three cross-cutting expectations sit over everything: act in good faith, avoid foreseeable harm, and support clients in pursuing their financial objectives. Every review should be able to speak to those, not just to whether a process was followed.
Map each case to the four outcomes
The Duty breaks into four outcomes: products and services, price and value, consumer understanding, and consumer support. For an advice firm most of the weight lands on suitability, on whether the advice represented fair value, and on whether the client genuinely understood the recommendation.
Tag each case against the outcomes it engages, so your evidence maps to the framework the regulator uses rather than a narrative you have to translate under pressure.
Build the evidence into the review
The firms that struggle treat the Duty as a reporting exercise bolted on at year end. The firms that cope capture the evidence as the advice is reviewed: the suitability rationale, the fair-value assessment, and the check that the client understood, all recorded on the case at the time.
Done this way, the annual board report is an aggregation of records you already hold, not a reconstruction of a year of decisions.
Do not under-evidence vulnerable customers
Fair treatment of vulnerable customers is where most firms’ evidence is thinnest. A policy is not enough. You need to show, case by case, how a vulnerability was identified, what adjustment you made, and that the outcome was still good.
Flag and route those cases for closer review and record the extra care, and a stated commitment becomes provable practice.
What the board report actually needs
A defensible report shows outcomes across client groups, evidence of both good and poor outcomes and what you did about the poor ones, your fair-value conclusions, and the actions taken where harm was foreseeable. Trend it over time so a direction of travel is visible.
If any of that has to be assembled by hand from separate systems, it will be late, incomplete and hard to stand behind. Keep it flowing out of the reviews.