The Chartered Insurance Institute's (CII) latest roundtable has highlighted the continuing hurdles insurers and intermediaries face in embedding the Financial Conduct Authority's (FCA) Consumer Duty.
The session brought together insurance professionals, financial planners and FCA representatives to review the first wave of Consumer Duty Board reports and set priorities for the next cycle.
Data and vulnerability remain key gaps
Participants identified data as the most pressing challenge, with many firms still reliant on manual processes that limit their ability to track customer outcomes. Automation and integrated systems remain longer-term goals, but most insurers are still in the early stages of development.
The roundtable also pointed to a lack of consistency in defining and addressing customer vulnerability. Frontline staff are often left to identify risks without the right tools, while the application of vulnerability principles to small and medium-sized enterprises remains unclear.
Distribution chains and reporting pressures
Concerns were raised about inconsistent data-sharing across the distribution chain, leaving gaps in outcome reporting.
Many insurers and brokers struggle to access reliable information from partners, creating difficulties in presenting a coherent view to boards and regulators.
This uneven flow of data risks exposing firms that cannot demonstrate customer value across the full journey. FCA representatives stressed that Consumer Duty should not be reduced to a compliance exercise, but instead should influence how firms design products, monitor outcomes, and deliver value.
Implications for insurers
The insights suggested that insurers will need to strengthen customer data strategies, with a sharper focus on segmentation and vulnerability analysis. Greater collaboration with brokers is also likely, as firms will need closer alignment on reporting standards and customer outcome evidence.
For boards, the expectation remains that they actively challenge management and ensure robust evidence supports claims of fair treatment.
While the roundtable showed that progress has been made since the first reporting cycle, the discussions made clear that Consumer Duty is still evolving. Addressing the persistent gaps in data, vulnerability management, and distribution reporting will be essential for insurers aiming to meet both regulatory expectations and customer needs.
