Data is one of the key challenges when it comes to producing Consumer Duty Board reports, according to a new study from the Chartered Insurance Institute (CII).
The report found that the obstacles include uncertainty over what data to include, the availability of appropriate data and how to integrate the data.
There has been an increase in firms reporting difficulty in showing the relationship between different data sets and manually entering data since 2024.
The report was based on a survey of 337 CII members taken in July 2025. The CII also recently hosted a roundtable discussion to examine the results.
Insurance and financial planning professionals, alongside FCA representatives, met to share insights and develop practical recommendations for the 2026 reporting cycle.
Research did find, however, that there was an overall improvement across six of the eight areas assessed.
These included ‘getting buy-in from colleagues to provide data’, and ‘explaining why some data gaps exist’.
In December 2024, the FCA found the areas for improvement included a lack of challenge from the Board, taking effective action and analysis of different customer segments.
By reviewing the data, the roundtable discussed the need for developments such as cross-sector standardised templates and metrics to make data sharing more efficient and reducing 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 CII has committed to use its independent convening role to facilitate further discussion, including:
- Leading stakeholder collaboration
- Publishing vulnerability management and GDPR guidance
- Enhancing professional standards
- Conducting lived experience research
CII chief executive Matthew Hill 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.”
