Context
A new report from the Chartered Insurance Institute (CII) highlights the key challenges faced by firms when producing Consumer Duty Board reports. ‘Knowing what data to include’, ‘Availability of appropriate data’, and ‘Integrating data’ were some challenging areas, with 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.
The data revealed some encouraging progress, with firms reporting overall improvement across 6 of the 8 areas assessed, including ‘Getting buy-in from colleagues to provide data’, and ‘Explaining why some data gaps exist’.
Key points to note and next actions
- In reviewing the data, 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. The report suggests that meaningful progress in Consumer Duty reporting will require ‘continued collaboration between sector stakeholders where good practice is shared’. The CII has committed 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: 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.