Bureau benchmarking for better decisions: Improve governance and meet regulatory expectations

Benchmarking is often associated with cost control. And for good reason — many firms uncover significant pricing variation in their bureau contracts, even when services appear identical.

But the value of benchmarking doesn’t stop at commercial savings.

It can reveal where your current data configuration might be introducing risk: from outdated inputs and missed fraud signals to compliance blind spots. As regulatory and operational pressures grow, these weaknesses affect decision quality, audit readiness, and strategic direction.

With tighter expectations around affordability, vulnerability and governance, many organisations are revisiting the structure and suitability of their bureau arrangements. But without a clear view of what others in the market are doing, it’s difficult to assess whether a setup is still working.

Benchmarking helps tackle that. And it gives teams a more robust foundation for defending the decisions they make. Here’s how:

1. Keeping pace with Consumer Duty

Affordability and vulnerability remain core regulatory concerns and the upcoming July 2025 Consumer Duty board reporting deadline is sharpening focus across sectors.

To meet expectations, firms need to show how their data supports fair outcomes. That means going beyond commercial value and looking at whether the inputs used for affordability and creditworthiness are still appropriate.

Yet, in practice, many organisations are working with bureau data that lacks granularity. Gaps in income insight, outdated indicators of financial stress, or limited coverage of key groups can all affect the quality of outcomes.

Benchmarking helps teams assess whether their current setup aligns with the standards being set elsewhere in the market and whether peers are introducing additional sources or taking a more layered approach.

After reviewing 180 board reports in late 2024, the FCA noted that some firms were still struggling to evidence data quality decisions. Its subsequent guidance makes clear that governance around data inputs is now a priority.

Where gaps are known, the risk ultimately rests with the firm — not the provider. Benchmarking provides a practical way to evaluate whether existing data sources are defensible.

2. Fraud resilience starts with data visibility

Benchmarking is increasingly being used as a tool for fraud teams to review coverage. Without this lens, it’s easy to assume bureau data provides complete protection, but that isn’t always the case, particularly for digital journeys, synthetic identities, or thin-file segments.

Cifas’s Fraudscape 2025 report paints a stark picture:

• Over 421,000 fraud cases reported in 2024 — up 13% year-on-year
  
  

• 76% increase in account takeover attempts
  
  

• 1,055% rise in SIM swap fraud, affecting thousands of airtime accounts

These changes highlight how quickly fraud typologies evolve and how easily blind spots can be missed.

Benchmarking gives firms a way to compare how their data stack performs against peers and to identify where enhancements could reduce exposure. That might mean supplementing bureau data with niche providers, revising onboarding logic, or flagging risk at an earlier stage in the journey.

3. Supporting defensible, auditable decisions

As audit and regulatory reviews become more focused on data governance, firms are expected to justify not only what data they use, but why those choices were made and how they compare to alternatives.

Benchmarking supports this process by creating a record of data decisions grounded in external reference points. It helps firms move away from legacy logic or internal preferences and toward a more structured, evidence-led approach.

We’ve seen this play out during model refreshes and validations, where benchmarking has been used to explain dual-provider models. In one example, a firm retained a core bureau for primary decisioning but used a second provider to support affordability checks. The rationale was accepted by auditors and enabled the firm to proceed without remediation.

4. Driving smarter data strategy

Beyond audit, fraud and regulatory pressure, benchmarking also helps firms take a broader view of how well their bureau strategy is working.

It may highlight underused data sets, overly complex contract structures, or areas where different providers offer stronger performance for specific use cases, such as younger customers, higher-risk segments or fast-growing digital propositions.

For example, some lenders operating in BNPL or motor finance have used benchmarking to explore whether their data setup supports accurate decisions across the full risk spectrum. In many cases, it prompts a move toward multi-bureau or hybrid strategies that offer greater flexibility and precision.

Changing providers, therefore, goes beyond cost saving. It allows firms to understand where small changes could unlock measurable improvements in performance and governance.

Final thought

The original goal of bureau benchmarking may have been cost reduction. But its role is now broader and more strategic.

Whether the focus is compliance, fraud, audit readiness or optimisation, benchmarking gives firms the information they need to make — and stand behind — stronger data decisions.

In a market where regulatory expectations are rising and internal accountability is growing, that kind of visibility is fast becoming essential.