Insurance firms face challenges in proving good customer outcomes under Consumer Duty

The Chartered Insurance Institute (CII) has warned that insurance and financial planning firms continue to face practical challenges in proving that good customer outcomes are being delivered in Consumer Duty board reporting. 

A report published today (2 September 2026) and called Consumer Duty Board reporting: two years on – from reporting to proving outcomes, is based on the CII’s third annual roundtable discussion examining how firms are approaching Consumer Duty governance and reporting.

The CII found that firms are producing more mature and data-driven board reports than in previous years, with concerns around understanding regulatory expectations becoming less prominent.

However, significant operational challenges remain.

Around three quarters of firms participating in the research cited difficulties around integrating data, sourcing appropriate information and linking datasets effectively. The report also highlighted ongoing challenges in evidencing customer understanding and demonstrating the impact of interventions designed to improve outcomes.

Practical guidance

The roundtable, held in July 2026, brought together representatives from the FCA alongside participants from insurance, financial planning, compliance, customer insight and professional standards.

According to the report, firms were more likely to have processes for responding to customer misunderstanding than systems capable of identifying it in the first place.

Participants highlighted the need for better testing at key customer decision points, clearer outcome measures and a more joined-up approach to analysing customer behaviour data.

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.”