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Collections & Field

Is Your Evidence Enough for Consumer Duty Compliance?

As a regulated business, would you consider turning off your call recording system and simply hope your team could remember what was said? Of course not. Without recordings, you would not be able to reliably assess what was said, what advice was given, how a customer was treated or whether you met the right standards.

Now imagine that every type of customer interaction went unrecorded. No audio, no video, no detailed documentation. Could you satisfy yourself that you’re meeting Consumer Duty requirements? Or would you be comfortable relying on memory and trust alone?

This raises a critical question for every compliance and operations leader: when it comes to Consumer Duty, how much evidence is truly enough, and would your firm pass the test in today’s world?

Without robust evidencing systems, especially when relying on external partners, demonstrating good customer outcomes becomes a serious challenge.

The Consumer Duty Shift: Evidencing Good Customer Outcomes

The FCA’s Consumer Duty marks a major shift in financial services regulation. Under PRIN 2A and Principle 12, firms are no longer evaluated just on processes; instead, they must prove consistent delivery of good customer outcomes to ensure full FCA Consumer Duty compliance.

This includes all interactions carried out on your firm’s behalf, whether that be from staff members, appointed representatives or third-party partners. Every customer touchpoint must comply with Consumer Duty principles, making evidencing critical.

The FCA expects proactive monitoring and evaluation to ensure good outcomes. Simply documenting processes is no longer enough; firms must provide concrete evidence of delivering good outcomes. That’s why Equivo’s body-worn video and Quality Assurance (QA) systems capture and review every single interaction, giving firms confidence to meet and surpass regulatory standards.

Field Recording: Essential for FCA Consumer Duty Compliance

While the FCA does not explicitly mandate recording every field interaction, Consumer Duty principles make comprehensive documentation essential. Field visits, whether for debt recovery, enforcement or reconnections, are sensitive interactions that can affect customer outcomes and compliance.

Without detailed audio and video, how can firms verify what was said, how customers were treated, or if interactions met regulatory standards? This evidencing gap is especially concerning when external partners conduct field activities without reliable recording.

Equivo closes that gap. Our advanced body-worn video technology captures every interaction with exceptional clarity, creating a complete and verifiable record of events from start to finish. Securely stored and easily reviewable, this evidence gives firms the confidence to demonstrate exactly what was said, how customers were treated, and that regulatory standards were met.

When paired with our rigorous Quality Assurance processes, it not only safeguards compliance but also promotes transparency and builds trust, ensuring the safety and fairness of both customers and field agents. The result is a reliable, end-to-end solution for accountability and accurate documentation in even the most sensitive situations.

Outsourcing Compliance: Maintaining Control with Evidencing

SYSC 8 requires firms to maintain effective control over outsourced activities to ensure they meet regulatory standards. This includes assessing risks, monitoring performance and ensuring the third-party provider complies with applicable requirements. Without strong evidencing, oversight of partner performance and customer interactions can be lost, risking poor compliance and damaging reputation.

When external agents act on your behalf, their conduct directly affects your Consumer Duty compliance and reputation. Equivo’s body-worn video and Quality Assurance systems give you full visibility and control over outsourced activities, capturing every interaction with precision. This ensures partner performance can be monitored in real time, risks are mitigated early, and consistent quality standards are upheld which ensures we operate to keep your firm fully accountable and compliant.

Common Misconceptions About Consumer Duty Evidencing

Two common misconceptions continue to undermine the process of evidencing: the belief that data alone tells the full story, and the assumption that evidence is only necessary at the end of a case. These misunderstandings can limit the effectiveness of decision-making.

  • Low complaints mean safe operations
    Fewer complaints do not always guarantee good outcomes as customers may choose to delay or avoid complaining altogether, often due to frustration or a lack of confidence in the process. Under Consumer Duty regulations, businesses are required to proactively detect and address potential issues before they escalate. Our advanced tools support this by enabling early identification of problems through our robust Quality Assurance processes, ensuring a better experience for both businesses and customers.
  • No explicit recording requirement means no need for evidence
    Although there is no strict mandate to record every single field interaction or every single telephone call, firms are still required to demonstrate their compliance with regulatory standards. Consumer Duty emphasises delivering positive outcomes for customers, which makes comprehensive evidencing a critical component of meeting these requirements. Equivo’s always-on recording technology ensures that no interaction goes unrecorded, providing firms with the tools they need to not only meet compliance standards but to exceed them.

How FCA-Compliant Evidencing Drives Operational Excellence

Robust evidencing is more than just a compliance requirement. It provides clear, objective records that improve Quality Assurance and help firms demonstrate accountability with confidence.

  • Enhance Quality Assurance and training by providing objective feedback that identifies strengths and areas needing improvement for more effective coaching.
  • Enable proactive monitoring to detect issues early and support timely resolution, helping maintain performance and efficiency.
  • Support dispute resolution with clear, documented evidence that protects clients and customers and ensures fair outcomes.
  • Build regulatory confidence by delivering transparent evidence of positive outcomes, demonstrating accountability beyond process compliance.

Adopting comprehensive evidencing not only strengthens regulatory compliance but also promotes fairness and transparency in customer interactions, helping firms to manage sensitive situations responsibly and with confidence.

Equivo’s Expertise in FCA Consumer Duty Evidencing

Our body-worn video technology captures every field interaction in full, providing a clear and reliable record of events. These recordings are all reviewed through rigorous Quality Assurance, ensuring compliance and uncovering opportunities to improve future interactions. Our secure cloud data hosting protects sensitive information while meeting strict data protection and regulatory standards, giving clients complete oversight of field activities and the confidence to evidence positive customer outcomes.

Turn Evidencing into Your FCA Compliance Advantage

Consumer Duty requires clear and thorough evidencing of every customer interaction. Firms must have reliable systems to capture, store and review all interactions accurately to protect their reputation and meet regulatory expectations.

At Equivo, we provide trusted solutions that simplify compliance by ensuring every interaction is recorded and reviewed with precision. This gives firms the confidence to demonstrate they are meeting Consumer Duty requirements and building genuine customer trust.

Ask yourself, can you confidently evidence every interaction, including those managed by external partners? If there is any uncertainty, it’s time to act. We are here to help you strengthen your processes and implement robust evidencing aligned with Consumer Duty principles because your firm’s compliance and reputation depend on it.

Contact our team today to learn how Equivo can help you achieve evidencing excellence and set new standards in compliance and customer care.

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Andy is Managing Director of Equivo’s Collections & Field Division has responsibility for operations and service delivery for collections activity across the business. Andy always challenges standard industry practice while keeping fully abreast of regulatory requirements, beliefs that are core to Equivo's operation.