Consumer Duty reporting progress will require ‘collaboration’

Meaningful progress in Consumer Duty reporting will require “continued collaboration between sector stakeholders where good practice is shared”, according to a new report from the Chartered Insurance Institute (CII).

The CII surveyed members on the issue and then hosted a roundtable discussion to examine the results.

Some of the areas found to be the most challenging were “Knowing what data to include”, “Availability of appropriate data”, and “Integrating data.”

There was an increase in firms reporting difficulty in “Showing the relationship between different data sets” and “Manually entering data” since 2024.

The data revealed some encouraging progress, the CCI said, with firms reporting overall improvement across six of the eight areas assessed, including “Getting buy-in from colleagues to provide data”, and “Explaining why some data gaps exist.”

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 the report.”

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.

• Findings were drawn from a July 2025 survey of CII members, with 337 responses.