Key challenges in Consumer Duty board reporting revealed

Issues around data has been cited as a key challenge when producing Consumer Duty board reports.

The Consumer Duty rules came into force in July 2023 and set out requirements that firms must follow to deliver good outcomes for their customers.

According to the Chartered Insurance Institute (CII), knowing what data to include, availability of appropriate data and integrating data were some of the areas found to be the most challenging when producing reports required by the regulation.

There was also 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.

Roundtable

In response to the findings, 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.

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.

Matthew Hill, CII chief executive, 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.”