Consumer Duty, Business Architecture and the Evidence Tax

The Financial Conduct Authority’s Consumer Duty has changed the conversation inside banks. For years, the question was whether an organisation complied with regulation. Today, the question is increasingly different: can we demonstrate, with evidence, that our customers are consistently receiving good outcomes?

That may sound like a subtle shift. In practice, it changes almost everything.

Banks have responded by creating programmes, governance forums, dashboards, outcome testing and assurance activities. All of these are sensible. Yet many organisations have discovered something unexpected. The hardest part isn’t understanding Consumer Duty. It’s finding the evidence.

The Evidence Tax

Every major bank already possesses enormous amounts of customer information: operational data, complaints, call recordings, quality assurance, customer journeys, management information, product governance, risk events, customer research, vulnerability assessments, financial crime controls and operational resilience metrics.

The problem is that none of these were designed to answer a single question:

Did this customer receive a good outcome?

Instead, each function collects evidence for its own purpose. Risk has one view. Compliance has another. Operations have a third. Product teams have a fourth. Technology owns different data again.

When regulators, executives or boards ask for assurance, organisations begin assembling evidence manually from dozens of disconnected sources. This is what I call the Evidence Tax. Not because the information doesn’t exist, but because every assurance exercise requires organisations to rediscover it.

Consumer Duty is exposing organisational design

One lesson has become increasingly obvious. Consumer Duty isn’t primarily testing products. It’s testing organisations. It exposes fragmented ownership, duplicated processes, inconsistent definitions and technology estates that have evolved over decades rather than being intentionally designed.

Many firms discover that nobody owns an entire customer journey. Different teams optimise different parts of the experience, yet nobody is accountable for the outcome from beginning to end. Consumer Duty didn’t create these organisational problems. It simply made them visible.

This is fundamentally a Business Architecture problem

Business Architecture is often misunderstood as producing capability maps or operating models. In reality, its purpose is to ensure the organisation is designed to deliver its intended outcomes.

Good customer outcomes depend on people, processes, technology, data, governance and decision-making working together. If any one of those elements becomes disconnected, evidence becomes fragmented and the organisation begins paying the Evidence Tax. Business Architecture provides the connective tissue between these moving parts. It defines ownership, clarifies accountability, aligns processes, creates common information models and makes evidence traceable rather than reconstructed.

AI changes the economics

Artificial Intelligence introduces an interesting possibility. Historically, assembling evidence has required people manually searching multiple systems, interpreting documents and reconciling inconsistent information. Generative AI and agentic AI have the potential to dramatically reduce the effort required to locate, connect and explain evidence that already exists across the organisation.

Imagine asking:

Show me every piece of evidence supporting good outcomes for vulnerable customers applying for personal loans over the last six months.

Or:

Explain why complaints increased following this policy change.

The underlying information may already exist. The challenge has always been connecting it. AI may finally make that economically practical, though as I argue in Agentic lending, an organisation still has to be designed so that the evidence can be reconstructed in the first place.

The real opportunity

Consumer Duty shouldn’t be viewed as another regulatory programme. It is forcing organisations to answer a much bigger question: how well is the bank actually designed to deliver consistently good customer outcomes?

That isn’t purely a compliance issue. It’s an organisational design issue. And that makes it a Business Architecture problem.

The firms that succeed won’t necessarily be those with the biggest compliance teams. They’ll be the ones that reduce the Evidence Tax by designing organisations where evidence is generated naturally as part of delivering good customer outcomes, rather than reconstructed afterwards.