A new report from the Chartered Insurance Institute (CII) highlights the key challenges faced by firms when producing Consumer Duty Board reports. ‘Knowing what data to include’, ‘Availability of appropriate data’, and ‘Integrating data’ were some of the areas found to be the most challenging, with an increase in firms reporting difficulty in ‘Showing the relationship between different data sets’ and ‘Manually entering data’ since 2024.
Findings were drawn from a July 2025 survey of CII members, with 337 responses. The CII hosted a roundtable discussion to examine the results, which detailed progress and ongoing challenges of Consumer Duty Board reporting, one year after firms submitted their first mandatory reports.
Insurance and financial planning professionals, as well as FCA representatives joined the discussion to share insights, and develop practical recommendations for the 2026 reporting cycle.
The data revealed some encouraging progress, with firms reporting overall improvement across 6 of the 8 areas assessed, including ‘Getting buy-in from colleagues to provide data’, and ‘Explaining why some data gaps exist’.
The roundtable follows a review of 180 Consumer Duty Board Reports in December 2024, in which the FCA found some examples of good practice, such as good quality data, analysis of different customer types, and a focus on clear outcomes. Areas for improvement included a lack of challenge from the Board, taking effective action, and analysis of different customer segments.
The path to progress in Consumer Duty reporting
In reviewing the data, roundtable participants discussed the need for developments such as cross-sector standardised templates and metrics to make data sharing more efficient, and reduce misunderstandings between firms and distributors. Sector wide frameworks that allow firms to pick metrics that are relevant to them while ensuring some degree of comparability, were also considered.
The report suggests that meaningful progress in Consumer Duty reporting will require ‘continued collaboration between sector stakeholders where good practice is shared’. The CII has committed to use its independent convening role to facilitate further discussion, including:
- Leading stakeholder collaboration: Convening a cross-sector working group (including consumers) to co-develop solutions for some of the challenges identified.
- Publishing vulnerability management and GDPR guidance: Soon to launch, the CII is developing good practice guidance on how to manage vulnerability and measure outcomes to meet regulatory requirements, as well as guidance on ensuring GDPR compliance while managing vulnerability data.
- Enhancing Professional Standards: Integrate Consumer Duty reporting good practice content within CII qualifications and Continuing Professional Development resources.
- Conducting lived experience research: Gather insights from individuals who have lived experience of vulnerability, to inform the development of our guidance.
Matthew Hill, CII Chief Exec, said: “While it is encouraging to see some improvement across most categories, the data shows that firms continue to face challenges in producing Consumer Duty Board reports. A lack of clarity in reporting undoubtedly tells a broader story of firms’ abilities to achieve the goals intended with the FCA’s Consumer Duty guidelines. The CII will look to take every opportunity to support further progress through the commitments outlined in this report.”
The Consumer Duty Board reporting: One Year on report is available here.