The two Consumer Duty outcomes that are quantitative — and why they are the hardest to evidence
8 min readRead →
FairLedger auto-produces the quantitative evidence for the two Consumer Duty outcomes that require it — price & value, and products & services — and assembles the annual board pack the FCA now requires.
Most firms answer them manually, once a year, in spreadsheets that were never designed to withstand supervisory scrutiny.
Is what customers pay proportionate to the benefit they receive? The regulator expects a quantitative answer.
Are products serving the customers they are sold to? Target-market alignment must be evidenced, not asserted.
Both outcomes must be evidenced to the board and defensible to the FCA — every year, with methodology and audit trail intact.
Ingests pricing, cost and transaction data. Runs the fair-value calculations against defensible methodology. Produces per-product, per-segment evidence with a full methodology audit trail.
Ingests product taxonomy and customer usage data. Tests target-market alignment, utilisation and mis-selling risk. Produces evidence of who products are — and are not — serving.
Designed to the level of rigour a Consumer Duty Champion, a Chief Risk Officer and the FCA all recognise as defensible.
Secure API and file-based connections to your transaction, pricing and product data. UK-hosted throughout.
The engines run fair-value and products-and-services calculations against your data with an auditable methodology trail.
The board pack is generated and version-controlled. Every board or FCA question is one click from evidence.
Authorised PIs with active Consumer Duty obligations.
Authorised EMIs and Small EMIs.
ASPIs where Consumer Duty applies to in-scope products.
Where products reach end-customers via agents and distributors, the chain-visibility module carries fair-value evidence along the chain.
UK data residency by default across production systems.
Aligned from Day 1; certification target Year 1 Q4.
Certification route documented; target Month 6.
Independent validation posture on the fair-value engine.
Design partner cohort is open. References from live engagements are provided under NDA in the discovery call.
As firms join FairLedger, anonymised fair-value baselines accumulate into a payments-specific benchmark set no incumbent RegTech is positioned to build. Your board pack does not just answer are our prices fair — it answers are they fair relative to comparable firms in our segment.
Benchmarks are contribution-only, tenant-anonymised, and governed by the same minimum-necessary-data principles as the primary ingestion pipeline. Full detail in the methodology appendix.
Consumer Duty explicitly covers the distribution chain — agents, programme managers, distributors, BaaS partners. Most fair-value work stops at the manufacturer boundary. FairLedger's chain-visibility module carries the price, fee and outcome evidence through to the end customer, per agent and per programme.
For BaaS providers and PIs with agent networks, this is the module the FCA is most likely to test — and the one manual processes struggle hardest to answer.
No open-ended consulting, no per-seat pricing games. A fee-bearing three-month pilot to prove value on your data, then an annual subscription.
Fixed-fee pilot on your real transaction and pricing data. First board pack delivered inside the pilot. Convertible into an annual subscription.
Indicative bands from c. £15k–£25k per firm per year, scaled to firm size, transaction volume and modules in scope.
Additional outcomes, entity types (PSPs, BaaS programmes) and frameworks reuse the same engine. Contracted at renewal.
Design partner cohort places carry a preferential pilot fee and locked-in Year-1 subscription pricing. Terms discussed on the discovery call.
FairLedger is founded by Okechukwu Ezeobele, a senior software engineer with a background across payments engineering (Bud), IT risk audit (PwC) and regulated public-sector software delivery. FairLedger is the productisation of the discipline he has been building — applied to a Consumer Duty gap he saw firms addressing manually.
About the founder →A discovery call runs 30 minutes and covers your Consumer Duty evidencing approach, the FairLedger fit and the design partner terms.