Agentic UK Consumer Duty (FCA PS22/9) annual board report, customer outcome monitoring data pack, and FCA supervisory request response service for small FCA-authorised firms — small IFAs, credit brokers, and consumer credit firms (1–20 staff) required to produce an annual Consumer Duty board report by 31 July each year. Replaces the compliance consultant who charges £1,500–£4,000 to produce the outcome monitoring evidence, draft the board report narrative, and respond to FCA Dear CEO letters.
Why now
No fresh signal batch provided. Justified by FCA's Consumer Duty implementation timeline — first annual board reports were due 31 July 2024, second cycle due 31 July 2025, with FCA supervisory visits to small firms accelerating (https://www.fca.org.uk/firms/consumer-duty). FCA published its Consumer Duty findings report in February 2025 flagging widespread board report deficiencies at smaller firms.
Source signals
https://www.fca.org.uk/firms/consumer-duty
Commercial value
~28,000 FCA-authorised small firms must produce a Consumer Duty board report annually. Compliance consultants charge £1,500–£4,000 per report; ongoing retainers £500–£1,500/month. ACV target £800/year for annual report + £150/month for ongoing monitoring alerts. Budget line: currently paid to compliance consultants, T&C supervisors, or law firms. FCA enforcement for Consumer Duty failures is escalating in 2025.
Go-to-market
Target small IFAs and credit brokers via FCA Financial Services Register (publicly searchable, ~28,000 small firms). Cold email with 'Consumer Duty board report readiness checker' (free 5-question quiz). Price: £797 one-time annual report pack, £149/month monitoring. Partner with AR network compliance officers. First 10 via LinkedIn targeting 'compliance officer' + 'small IFA' UK.
2-week MVP
5-question intake form (firm type, customer segments, complaint data, outcome testing done Y/N, prior FCA correspondence) feeding an LLM that produces a Consumer Duty annual board report draft in FCA-expected structure (four outcome areas: products, price, consumer support, communications). Cut: no live data integration, no FCA portal submission, no ongoing monitoring. Manual compliance review before delivery. Day-1 outcome: small IFA receives a compliant board report draft they can present to their board before the 31 July deadline, replacing the £2,000 consultant engagement.
Agent score
0.68 — Commercial: 28,000 addressable FCA small firms, hard annual deadline creates recurring urgency, £800+ ACV plausible and matches existing consultant spend. Speed: intake form + LLM report generation is a 1-week build; FCA register gives a cold outreach list. Defensibility: annual deadline creates recurring revenue but low switching cost; moat builds if proprietary FCA enforcement pattern library is accumulated.
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