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Security and compliance

Consumer Duty and FCA evidence engineering

Consumer Duty evidence engineering is the work of making a firm’s systems produce the evidence the FCA’s Consumer Duty and operational resilience rules require, rather than assembling it by hand before a review. That means recording how customers are treated at each step, how products perform for different groups, how vulnerable customers are identified and supported, and how important business services behave under stress against the impact tolerances the firm has set. Hexploits builds this into the systems that already run the business.

A named engineer replies within one working day. A written scope and an indicative price within two.

  • Lenders, payment firms, insurers and wealth businesses under the FCA’s Consumer Duty since July 2023 for open products and July 2024 for closed ones.
  • Firms subject to the FCA and PRA operational resilience rules, with impact tolerances that had to be met by March 2025.
  • Compliance and risk functions asked to produce the annual Consumer Duty board report from systems that were never designed to provide it.
  • Checkout and onboarding owners whose flows decide, in practice, whether customers get good outcomes.

Deliverables, not slogans. Each one appears in the statement of work.

  • Outcome data captured at the point it happens: product and price decisions, communications sent, support offered, complaints raised, and what changed as a result.
  • Vulnerability identification and support flags built into onboarding, servicing and collections flows, with the treatment recorded.
  • Management information for the annual board report, produced from live data with the definitions written down.
  • Mapping of important business services to the systems and suppliers they depend on, with monitoring against impact tolerances.
  • Scenario testing and evidence of behaviour under stress, run on a schedule rather than once.
  • A change process that records the Consumer Duty assessment for every product, price or journey change.

Our engineers work across the major languages, frameworks and cloud platforms. We build on the stack you already run, with technology choices explained in writing before work begins.

The same four stages as every Hexploits engagement, applied to this capability.

  1. Stage 1

    Discovery

    Two to four weeks. We map customer journeys, the outcome data each should produce, the important business services and their tolerances, and where evidence is currently assembled by hand. Output: a gap list ranked by regulatory exposure and a fixed figure or capped estimate.

  2. Stage 2

    Build

    Instrumentation and data capture added to the existing systems, management information built from it, and resilience monitoring wired to the services that matter.

  3. Stage 3

    Launch

    A first board-report data pack produced from the new evidence and reviewed with compliance before it is relied on.

  4. Stage 4

    Operate

    Scheduled scenario tests, MI refreshed automatically, and the evidence kept current as products and journeys change, under deployment and monitoring.

Regulated customer journeys at Modulr Finance, Apexx Global and Holland & Barrett

Our core team built customer-facing payment and checkout systems inside FCA-regulated and PCI-scoped businesses before Hexploits: onboarding and payments at Modulr Finance, payment flows at Apexx Global, and the checkout and basket at Holland & Barrett. Good customer outcomes are decided in those flows, and the evidence has to come from them.

Every engagement agrees its measures and the measurement period in writing before work starts.

  • Time to produce the Consumer Duty board report, measured before and after.
  • Share of outcome evidence produced by systems rather than assembled by hand.
  • Impact tolerance breaches detected by monitoring before they are reported by customers.
  • Findings from internal audit or the FCA that relate to missing evidence.

Case studies with numbers, and reviews linked to Google where they were left there.

  • Director, Lothbury

    Top quality delivery, and reasonable price. Will be using again.

    Peter DentonDirector, LothburyRead the review
  • Director, IO Solutions

    Fantastic to work with. High level of attention to detail and flawless communication throughout. Would recommend to anyone looking to develop or improve a software product.

    Christian LorzaDirector, IO SolutionsRead the review
What does the Consumer Duty actually require of our systems?
The Duty itself is outcomes-based: products and services, price and value, consumer understanding and consumer support. In practice the FCA expects firms to monitor and evidence those outcomes with data, including for vulnerable customers, and to report to the board annually. Systems that do not record what happened to customers cannot produce that evidence.
What are impact tolerances?
Under the operational resilience rules, firms identify their important business services and set the maximum tolerable disruption for each. Firms had to be able to remain within those tolerances by 31 March 2025 and must test that they can. Monitoring and scenario testing are how you show it.
Is this legal or compliance advice?
No. We do the engineering that produces the evidence and work alongside your compliance function and counsel, who own the regulatory position. Definitions for management information are agreed with them and written down.
Does DORA apply to us as well?
DORA applies to financial entities in the EU and their ICT providers from January 2025. UK firms with EU entities or EU clients are often in scope for part of their estate. The evidence built for FCA operational resilience covers much of what DORA asks for, and we map the two so the work is done once.
Can this be added to systems a previous supplier built?
Yes. Most of the work is instrumentation and data capture around existing flows. Where the code cannot safely be changed, we start with a stabilisation phase, documented on the rescue and stabilisation page.

Request a proposal.

Tell us about the system and the sector. A named engineer replies within one working day. A written scope and an indicative price within two working days of a short scoping call.