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A Five Step Blueprint for Becoming FCA Evidence Ready by 2026

Charlotte Bailey Chief Executive Officer
Publish date: 11th December 2025

If you are waiting for the FCA to tell you that your evidence is not good enough, you are already too late. The regulator has been unequivocal in its Strategy 2025 to 2030. It expects firms to demonstrate outcomes with accuracy, traceability, and consistency. Evidence is no longer a supporting asset. It is the basis on which your organisation will be judged. Many firms still operate on an outdated assumption that policies, governance frameworks, and documentation will protect them during supervisory scrutiny. They will not. The FCA has stated clearly in its Consumer Duty Data and Insights review that poor quality MI remains a primary driver of consumer harm. If your board cannot trust the MI you present, the FCA will not trust the evidence you submit. Evidence readiness is not optional. It is the regulatory minimum. 

Step One: Establish a Single Version of the Truth for FCA Evidence Readiness:


You cannot evidence outcomes when different teams are reporting different versions of reality. The FCA’s 2025 Retail Banking Portfolio Letter notes that inconsistent definitions, fragmented systems, and unreliable MI remain widespread across the industry. If your affordability metrics differ between CRM and core banking, or if vulnerability flags change depending on which department produces the report, you are already non compliant in practice, regardless of how strong your documentation appears. High performing firms operate from one truth. Underperforming firms operate from several and hope no one notices. FCA Evidence ready firms have one governed layer, one definition of every metric, and one authoritative narrative that does not change by system or department. Without this, every attempt to satisfy Consumer Duty collapses before it begins. 

Step Two: Implement End to End Lineage and Transparency

Transparency is no longer a nice to have. It is a regulatory expectation. The FCA’s Consumer Duty Insights publication is explicit that firms must understand how their data is created, transformed, and used to assess outcomes. If you cannot trace a single metric from a report back to its source, including all intermediate transformations, you are not evidence ready. If two systems produce different answers and you cannot explain why, you are not evidence ready. If your product, risk, and compliance teams cannot articulate the origin and meaning of each field influencing customer outcomes, you are not evidence ready. Evidence readiness requires continuous lineage. Without it you cannot defend your decisions because you cannot prove how they were made. 

Step Three: Automate Validation and Eliminate Manual Reconstruction

Every manual adjustment you tolerate is a control failure you have accepted. The FCA consistently highlights in its Business Plans that manual processes and weak validation undermine effective governance. When your analysts must copy, paste, cleanse, or manually interpret data, they create untraceable decision points and destroy reproducibility. Automation is not about speed. It is about defensibility. Evidence that cannot be recreated exactly will not be trusted. Evidence that depends on a person’s recollection will not be accepted. Evidence that requires reconstruction is evidence that has already failed. Validation must be automated at the point of ingestion, transformation, and consumption. If your data cannot validate itself, your regulator will be forced to question whether you can validate your own controls and your evidence-based compliance approach.

Step Four: Build Reproducible Outcome Testing and Fairness Analysis

Consumer Duty has shifted the burden of proof. It is not enough to claim your products are fair. You must prove it. The FCA’s expectations for outcome monitoring require firms to identify foreseeable harm, demonstrate consistency across cohorts, and evidence that customer experiences match the firm’s stated intentions. You cannot do this with fragmented logic or inconsistent definitions. Reproducible testing means that every outcome, every scenario, and every fairness analysis can be run repeatedly with identical results. It removes variation caused by human interpretation. It eliminates discrepancies between teams. It ensures that fairness is demonstrated through evidence rather than presented as opinion. High performing firms understand that reproducibility is the new compliance discipline. It is the difference between knowing your customers are treated fairly and hoping they are. 

Step Five: Move to Real Time or Near Real Time Supervisory Readiness 


Supervision is shifting from retrospective explanation to immediate verification. The FCA’s work on Digital Regulatory Reporting signals a clear direction. The regulator wants machine readable evidence that can be tested instantly, not reconciled manually. If your organisation requires days or weeks to compile MI, you are already behind. Evidence readiness by 2026 means being able to answer supervisory questions with governed, consistent data on demand. It means replacing reconstruction with retrieval. It means your organisation is prepared for a world where the FCA identifies issues through data long before it engages with your teams. If your response to a supervisory query begins with “We need time to align the data,” you are not evidence ready. You are exposed.

The Implication of Doing Nothing

If you change nothing, the consequences do not stay the same. They compound. Your definition gaps will widen. Your ability to identify foreseeable harm will weaken. Your MI will present contradictions the FCA will immediately notice. Your outcome monitoring will become increasingly indefensible. And each time the regulator requests evidence, your organisation will be forced to rebuild the truth manually. At that point, the failure will not appear operational. It will appear cultural. The FCA’s 2025 to 2030 Strategy confirms that it will use data and analytics to identify firms whose actual customer outcomes diverge from their stated claims. In other words, if your evidence is weak, the FCA will already know. 

Where Panintelligence Makes Evidence Readiness Possible

Panintelligence does not make you slightly more compliant. It removes the weaknesses that create non compliance. It unifies fragmented data into one governed evidence layer. It enforces consistent definitions across teams. It provides full source to output lineage. It eliminates manual reconciliation by validating data continuously. It makes outcome testing reproducible and defensible. It generates regulator ready MI instantly, not after reconstruction. And it integrates seamlessly with your existing systems so you gain evidence readiness without architectural upheaval. Panintelligence gives you the ability to prove outcomes, not explain them. In a world moving towards real time scrutiny, that capability is not an advantage. It is a necessity. 

Evidence Is the New Currency of Credibility

The regulator is no longer asking whether your decisions are right. It is asking whether you can prove they are right. If you cannot, you already have your answer. Evidence readiness by 2026 is the difference between firms that will withstand increased scrutiny and those that will be exposed by it. The firms that win will be the firms that can prove the truth. Panintelligence gives you that capability. Evidence is not compliance paperwork. Evidence is the foundation of trust.  

By 2026, it will also be the basis of your regulatory survival. 

Topics in this post: 
Charlotte Bailey, Chief Executive Officer Results-driven, customer-focused, and technologically savvy, Charlotte Bailey is Panintelligence's energetic CEO. Charlotte is a senior change-maker with a keen understanding of analytics and big data, with over a decade of Customer Success, Development, and Product Management experience. By analysing situations and examining problems in granular detail, she provides fresh perspectives while harnessing new technology. Her purpose is to provide clear strategic leadership and collaboration with customers to develop, transform and simplify operations and technology to deliver measurable benefits - and getting to play with cool toys along the way! View all posts by Charlotte Bailey
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