Many advisers will say that they were already following the principles of consumer duty long before the regulator gave it a name. However, the real change lies in proving it: how can advisers show that they have delivered against client expectations? Evidence needs to be increasingly granular, demonstrating how advisers arrived at a particular decision, the trade-offs that were considered, and how the outcomes matched the client’s expectations.

Since the introduction of the Financial Conduct Authority’s (FCA) Consumer Duty framework in 2023, it has been clear that simply sending clients a hefty packet of supporting documentation is not enough to constitute evidence for recommendations. Every piece of evidence needs to be made with the client’s “needs, characteristics and objectives” in mind, according to the FCA. Advisers must make sure that the messages they send are the same as those received by the client, and that they can evidence that clients understand what they are being told.

This is not easy. The regulator requires advisers to capture how clients behave “at every stage and in each interaction”. It also expects advisers to acknowledge that investors are susceptible to cognitive and behavioural biases. Additionally, outcomes will need to be monitored over time, not just at the point of advice.

Defining a good customer outcome is the starting point. This involves setting clear metrics, agreeing the thresholds for action, and recognising that outcomes may vary across different customer groups, including those with vulnerabilities.

These outcomes will need to be agreed with clients at the outset, with evidence that they understand them. They will not be purely financial: confidence, understanding and peace of mind are also valid outcomes of advice. Whatever is agreed, evidence is what makes those outcomes visible to clients, firms and regulators.

Technology as an enabler

Technology is part of the solution. In the latest research from BNY Investments and NextWealth – “Retirement Advice in the UK: Turning Insight into Outcomes”, advisers describe how the adoption of Consumer Duty has prompted a rethink on the importance of management information and data. One independent financial adviser said: “Our data set has gone into granular detail because we saw from the survey that recently came through from the FCA that if you haven’t got that sort of linear granular information, you’re struggling.

“You need to have so much more at your fingertips. The PI [professional indemnity] insurers want to know about it as well. Whenever we renew our PI, they want to know how many people went into drawdown, how many people went into EIS [enterprise investment schemes], how big were their pots when they went into drawdown.”

Technology does not only help with providing the numbers. One of the primary uses for artificial intelligence (AI) among financial advisers to date has been in capturing evidence of consumer preferences, expectations and behaviours. The research indicates that around three-quarters of advisers are currently using, or thinking of using, AI for meeting notes and summaries. This is by far the most common use of AI by advisers, but suitability and vulnerability assessments are also important areas of AI development.

The growing role of narrative evidence

However, financial advisers emphasise that technology alone is not enough. Good practice also involves clear narrative evidence showing how advice decisions were reached, which alternatives were considered, and how outcomes align with client priorities.

One chartered financial planner said: “It’s more driven by Consumer Duty than the retirement income review. Whether it’s an annual review or new business, there’s something called the case rationale, and it’s the four outcomes under Consumer Duty: product suitability, understanding, value for money, etc. We’ve got to put narrative there about how we’ve met those or not. There’s got to be a ‘why’ for what you’re doing.”

Narrative evidence is becoming as important as quantitative metrics and fulfils a number of functions. It gives clients clarity and reassurance, helps advisers work more consistently, and supports firm-level oversight and regulatory compliance. Perhaps most importantly, it pushes advisers to understand what clients really value, which should ultimately improve satisfaction. The interviews made as part of the research show confidence, reassurance and peace of mind not as incidental by-products of advice, but as deliberate outcomes of the planning process itself.

Most advisers understand that clients do not come to them because they want a product, such as a pension or an ISA, but for financial security or to plan for their future. Often, clients do not know whether they are doing enough or doing the right thing. Building a narrative structure into advice helps meet regulatory obligations while keeping the focus on clients’ underlying goals. In this way, advisers can help their clients move from anxiety to informed confidence. One proposition lead said: “The value in financial planning is that peace of mind, telling them everything’s okay.”

Evolving client perceptions

Evidence may also need to reflect how clients’ priorities change over time. Survey results show satisfaction with retirement advice is often lower before and during the transition into retirement, when clients may feel less secure, but tends to improve once they are fully retired.

This suggests that clients may recognise value most clearly once uncertainty has eased, reinforcing the importance of supporting clients through the most anxious stages of the journey. It also shows that “softer” outcomes may take time to emerge, so the evidence gathered should reflect that.

The shift from rules-based to outcomes-based regulation has increased the need for evidence. Data can support this, but narrative explanations also have an important role to play. There are real advantages to getting this right, not only for regulatory purposes but also in helping advisers better understand what clients truly value. 

Research conducted by NextWealth for BNY Investments, based on responses to surveys with 207 retirement-focused financial advisers and 260 consumers of financial advice conducted in November 2025.