A new Chartered Insurance Institute (CII) roundtable report finds insurance and financial planning firms are making positive progress in Consumer Duty Board reporting, but continue to face practical challenges in proving that good customer outcomes are being delivered.
The Consumer Duty Board reporting: two years on – from reporting to proving outcomes, is published today following the CII’s third annual discussion on Consumer Duty Board reporting. The findings show that firms are increasingly producing more confident and data-rich reports, while looking for practical, proportionate support to help translate those reports into stronger evidence of customer outcomes.
Survey participants reported that challenges linked to unfamiliarity with regulatory expectations have eased, while structural issues remain. Around three quarters of firms highlighted difficulties relating to integrating data, sourcing appropriate data and connecting datasets. Firms are also working towards evidencing consumer understanding. Processes for responding to customer misunderstanding were found to be far more prominent than mechanisms to detect it in the first place, with firms pointing to the need for better testing at key decision points, clearer outcome measures and a more cohesive approach to customer behaviour data.
The session, held in July, brought together representatives from the Financial Conduct Authority (FCA) with participants from across insurance, financial planning, compliance, customer insight and professional standards. The FCA reinforced messaging on the shift from treating Board reports as compliance exercises to using them as governance tools that drive better outcomes and continuous improvement.
Firms also used the roundtable to underline the importance of proportionality, particularly for smaller businesses. Participants noted that smaller firms can be closer to their clients and better able to investigate individual outcomes, but may lack the scale, internal distance or research resource needed to test understanding and evidence outcomes in the same way as larger organisations.
Adam Harper, Executive Director of Strategy, Advocacy and Professional Standards at the CII, said: “The real test of Consumer Duty Board reporting is whether firms can use the evidence to understand where customers are experiencing poor outcomes and take meaningful action to improve them. The CII will build on this work with the development of further practical guidance to support firms as we strengthen our sector’s delivery in accordance with Consumer Duty.”
The CII has committed to continue its engagement with members, firms and the regulator to develop sector-specific support that reflects the practical realities firms face. This work will focus on helping firms use Consumer Duty reporting as a governance tool for continuous improvement, rather than as a compliance exercise.