Outcome testing under Consumer Duty: “The primary failure we do still see is colleague failures.”
Aptly summarised by ICA Compliance Consultancy Firm of the Year winners, Square 4 Partners, during our recent joint webinar in April 2026.
If financial services firms are not clear on just how critical it is to support colleagues to optimise their competence and confidence to deliver great customer outcomes under the Consumer Duty, then this two-minute insight provides some much-needed clarity.
Square 4 conduct a lot of outcomes testing within firms, and the majority of poor outcomes they see firms delivering to customers are split into two broad buckets:
❌ Bucket one: The policy, process, or control is deficient.
In these cases, colleagues are executing what has been provided to them, but the failure lies within the organisational design rather than the individual – and it creates a systemic issue.
❌ Bucket two: Employee competence is not maintained.
This is the most frequent issue of failure cited. Your colleagues may pass initial training and assessments, but they do not always retain that knowledge or feel able to apply it effectively during complex, real-world customer interactions.
The FCA has been explicit that it is not enough to simply tick a training box – authentic competence requires continuous reinforcement, assessment and a joined-up approach to outcome testing, QA, and journey reviews.