--- title: What are the primary challenges firms tell us they are facing? description: How does your Consumer Duty progress compare? Analyse sentiment data on reporting confidence and evidence gaps from our industry-wide webinar series. image: https://info.elephantsdontforget.com/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/HubSpot%20Landing%20Thumbnails/CDi%20Series.png --- [![CDi-Logo](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/CDi-Logo.png?width=350&height=97&name=CDi-Logo.png "CDi-Logo")](https://www.elephantsdontforget.com/consumer-duty-insight/) What are the primary challenges firms tell us they are facing? [Go back to homepage](https://info.elephantsdontforget.com/improving-organisational-competence-and-culture-to-support-good-customer-outcomes-under-the-consumer-duty?hsLang=en) [![CDi-i-Final](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/CDi-i-Final.png?width=150&height=251&name=CDi-i-Final.png "CDi-i-Final")](https://www.elephantsdontforget.com/consumer-duty-insight/) --- About **In module two, we examine feedback from our ongoing Consumer Duty webinar series. Since April 2025, we have captured 6,670 responses to key questions regarding firms' progress. This data provides both a sentiment check and a benchmark, allowing the industry to evaluate the effectiveness of their respective programmes from the start of this period to the present.** We explore critical issues concerning data integrity, reporting confidence, and existing evidence gaps. \*Please note that these data points will be updated in line with future webinars, ensuring firms can continue to check their progress against evolving industry sentiment. ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") September 2026 Focus Area: Consumer Duty Evidence Key Challenge: Evidencing good outcomes Findings & Industry sentiment: - 34% of 739 senior financial services professionals state that, if the FCA asked them to demonstrate that Consumer Duty is delivering good outcomes in practice, they would be able to show 'data showing what customers experience and can identify potential risks or poor outcomes, but the link to decisions and actions is not always clear'. - 24% state they can 'demonstrate that frameworks, policies, training and monitoring activities are in place, but have limited evidence of the outcomes customers actually experience'. - 23% state they can 'show how MI and root-cause analysis lead to decisions and interventions, but they do not consistently verify whether those actions improved customer outcomes'. - 14% state they can 'trace outcomes MI through to root cause, action and verified improvement, supported by relevant competence, QA and governance evidence'. - 5% state they would 'struggle to produce a convincing, joined-up evidence trail'. **Number of professionals polled:** 739 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty Outcomes Monitoring: Can you prove it’s working?’, September 2026. Poll results based on 739 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-outcomes-monitoring-can-you-prove-its-working/) September 2026 Focus Area: Consumer Duty Outcomes Key Challenge: Top-ranking improvement priorities   Findings & Industry sentiment: In rank order, 739 senior financial services professionals state that the top five highest-priority areas they plan to focus on to strengthen Consumer Duty outcomes monitoring are: - **1(Lead Answer)** Turn MI into meaningful action. - **2** Define good outcomes more clearly. - **3** Join up competence and outcome evidence. - **4** Verify that remediation works. - **5** Strengthen Board challenge and oversight. **Number of professionals polled:** 739 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty Outcomes Monitoring: Can you prove it’s working?’, September 2026. Poll results based on 739 responses. Multiple choice allowed. Rank order. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-outcomes-monitoring-can-you-prove-its-working/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") June 2026 Focus Area: Consumer Understanding Key Challenge: Evidencing communication comprehension Findings & Industry sentiment: - 49% of 484 senior financial services professionals state that ‘testing whether communications improve comprehension’ is the hardest area of consumer understanding for their firm to evidence. - 20% state ‘demonstrating governance and ownership of the outcome’. - 18% state ‘using MI and customer insight to drive design changes’. - 13% state ‘adapting journeys for vulnerable or low-capability customers’. **Number of professionals polled:** 484 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty: Say Less, Prove More – The New Standard for Consumer Understanding’, June 2026. Poll results based on 484 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-say-less-prove-more-the-new-standard-for-consumer-understanding/) June 2026 Focus Area: Evidencing Consumer Understanding to the Board Key Challenge: Over-reliance on back-end operational MI Findings & Industry sentiment: In rank order, 484 senior financial services professionals state they use these methods to evidence consumer understanding to the Board: - **1(Lead Answer)** Sales, complaints, and operational MI **(86%)**. - **2** Comprehension testing of communications and journeys **(38%)**. - **3** Frontline staff competence and decision-quality data **(29%)**. - **4** Behavioural and drop-off data segmented by customer group **(22%)**. **Number of professionals polled:** 484 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty: Say Less, Prove More – The New Standard for Consumer Understanding’, June 2026. Poll results based on 484 responses. Multiple choice allowed. Rank order. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-say-less-prove-more-the-new-standard-for-consumer-understanding/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") May 2026 Focus Area: Confidence in Year 3 Board Reports Key Challenge: Mixed confidence in reporting Findings & Industry sentiment: - 69% of 485 senior financial services professionals state they are ‘fairly confident \[about their Year 3 Report\], but there are gaps they know they need to close’. - 19% state they are ‘uncertain, I don’t know what I don’t know, or I'm not sure our report will stand up to scrutiny’. - 7% state they are ‘not confident, we have significant work to do’. - 2% state they are ‘very confident, we know what good looks like and we're on track’. - 2% state they are ‘not sure’. **Number of professionals polled:** 485 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty Board Reports 2026: From MI to Meaningful Challenge’, May 2026. Poll results based on 485 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-board-reports-2026-from-mi-to-meaningful-challenge/) May 2026 Focus Area: Consumer Duty Year 3 Board Reporting Key Challenge: Making meaningful changes that are aligned to FCA good practice and areas for improvement reviews Findings & Industry sentiment: In rank order, 485 senior financial services professionals state how aligned they are to making changes to their Board reports based on published FCA reviews: - **1(Lead Answer)** Work in progress, we know what needs doing. - **2** Partially, some gaps are closed, others are still open. - **3** Yes, we’ve made meaningful changes that we can evidence. - **4** Not yet, it’s on the list. - **5** Honestly, we’re not sure where we stand or where to start. **Number of professionals polled:** 485 Source: Elephants Don’t Forget Webinar, ‘Consumer Duty Board Reports 2026: From MI to Meaningful Challenge’, May 2026. Poll results based on 485 responses. Multiple choice allowed. Rank order. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-board-reports-2026-from-mi-to-meaningful-challenge/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") April 2026 Focus Area: Employee Competence & Outcomes Testing Key Challenge: Connecting the two disciplines together Findings & Industry sentiment: - 58% of 470 senior financial services professionals state that the two disciplines of employee competence and outcomes testing are ‘partially connected, some overlap but not consistent or joined-up’. - 28% state they are ‘largely separate, they run independently of each other’. - 9% state they are ‘not sure how connected they are’. - 6% state they are ‘fully connected, we already link learning and outcomes testing systematically’. **Number of professionals polled:** 470 Source: Elephants Don’t Forget Webinar, ‘From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice’, April 2026. Poll results based on 470 responses. Single choice allowed.  [Watch webinar](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice/) [Access paper](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice-2/) April 2026 Focus Area: Management Information (MI) Key Challenge: MI maturity highlights gap between data collection and the ability to evidence outcomes or resolutions. Findings & Industry sentiment: In rank order, 470 senior financial services professionals state that these are reflective descriptions of their Management Information at present: - **1(Lead Answer)** We have data but not conclusions. - **2** We track activity but not outcomes. - **3** We are in good shape. - **4** We identify issues but cannot show we fixed them. - **5** Our MI lacks thresholds and rationale. **Number of professionals polled:** 470 Source: Elephants Don’t Forget Webinar, ‘From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice’, April 2026. Poll results based on 470 responses. Multiple choice allowed. Rank order. [Watch webinar](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice/) [Access paper](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice-2/) April 2026 Focus Area: Regulatory Reporting Key Challenge: Difficulty providing comprehensive outcomes-based evidence to the regulator Findings & Industry sentiment: - 42% of 470 senior financial services professionals state that they would provide ‘a mixture of activity-based and outcomes-based evidence that wouldn’t tell the whole story’ to the FCA if the regulator asked for evidence of outcomes. - 33% state they would provide ‘good outcomes evidence’. - 21% state they would provide ‘activity evidence showing process completions and controls rather than outcomes’. - 4% state they are ‘not sure’ what they would provide. **Number of professionals polled:** 470 Source: Elephants Don’t Forget Webinar, ‘From MI to Meaningful Outcomes: Proving Consumer Duty Works in Practice’, April 2026. Poll results based on 470 responses. Single choice allowed.  [Watch webinar](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice/) [Access paper](https://www.elephantsdontforget.com/resources/from-mi-to-meaningful-outcomes-proving-consumer-duty-works-in-practice-2/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") March 2026 Focus Area: Firm Culture Key Challenge: Cultural factors creating the greatest risk to customer outcomes Findings & Industry sentiment: In rank order, 706 senior financial services professionals state that the top five cultural factors creating the greatest risk to customer outcomes in their firms are as follows: - **1(Lead Answer)** Poor ownership of recurring problems. - **2** Commercial pressure overriding good judgement. - **3** Weak escalation of customer issues. - **4** Incentives that drive the wrong behaviours. - **5** Lack of challenge and psychological safety. **Number of professionals polled: 706** Source: Elephants Don’t Forget Webinar, ‘Show Me the Outcome: Evidencing Culture Under the Consumer Duty’, March 2026. Poll results based on 706 responses. Multiple Choice allowed. Rank Order. [Watch webinar](https://www.elephantsdontforget.com/resources/show-me-the-outcome-evidencing-culture-under-the-consumer-duty/) [Access paper](https://www.elephantsdontforget.com/resources/show-me-the-outcome-evidencing-culture-under-the-consumer-duty-2/) March 2026 Focus Area: Consumer Duty Evidence Key Challenge: Monitoring outcomes with meaningful data Findings & Industry sentiment: - 56% of 706 senior financial services professionals state that ‘monitoring outcomes with meaningful data’ is the hardest aspect for their firm to evidence under Consumer Duty. - 16% state ‘defining what “good customer outcome” looks like’. - 15% state ‘proving governance challenge and oversight’. - 13% state ‘aligning incentives and behaviour with the Duty’. **Number of professionals polled: 706** Source: Elephants Don’t Forget Webinar, ‘Show Me the Outcome: Evidencing Culture Under the Consumer Duty’, March 2026. Poll results based on 706 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/show-me-the-outcome-evidencing-culture-under-the-consumer-duty/) [Access paper](https://www.elephantsdontforget.com/resources/show-me-the-outcome-evidencing-culture-under-the-consumer-duty-2/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") January 2026 Focus Area: Culture & Decision-Making Key Challenge: Evidencing the link between culture, decision-making, and customer outcomes Findings & Industry sentiment: - **8%** of 720 senior financial services professionals state they ‘can clearly evidence how culture drives decision-making and customer outcomes in practice’. - 33% state they ‘rely mainly on policies, training completion and engagement surveys’. - 43% state they ‘combine culture metrics with some outcome testing and MI’. - 16% state they either ‘haven’t tested this’ or ‘know it’s a weakness’ that requires remediation. **Number of professionals polled: 720** Source: Elephants Don’t Forget Webinar, ‘Kick-Start 2026: Conduct, Culture & Consumer Duty – What Firms Must Get Right’, January 2026. Poll results based on 720 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/kick-start-2026-conduct-culture-consumer-duty-what-firms-must-get-right/) [Access paper](https://www.elephantsdontforget.com/resources/conduct-culture-consumer-duty-what-firms-must-get-right-in-2026/) January 2026 Focus Area: Conduct & Culture Key Challenge: Demonstrating culture and the connection to outcomes  Findings & Industry sentiment: In rank order, 720 senior financial services professionals state that the top five biggest conduct and culture risks to delivering good customer outcomes in their firms are: - **1(Lead Answer)** Culture exists on paper but doesn’t shape day-to-day decisions. - **2** The firm hasn’t clearly articulated what “good outcomes” actually look like in practice. - **3** We lack credible evidence that culture supports fair value and good customer outcomes. - **4** Accountability is unclear when outcomes fall short. - **5** Leadership strategy and priorities don’t consistently reinforce good outcomes. **Number of professionals polled: 720** Source: Elephants Don’t Forget Webinar, ‘Kick-Start 2026: Conduct, Culture & Consumer Duty – What Firms Must Get Right’, January 2026. Poll results based on 720 responses. Multiple choice allowed. Rank Order. [Watch webinar](https://www.elephantsdontforget.com/resources/kick-start-2026-conduct-culture-consumer-duty-what-firms-must-get-right/) [Access paper](https://www.elephantsdontforget.com/resources/conduct-culture-consumer-duty-what-firms-must-get-right-in-2026/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") November 2025 Focus Area: Controls Key Challenge: Evidencing effectiveness of controls to the FCA Findings & Industry sentiment: - **25%** of 410 senior financial services professionals state that they are ‘not confident or unsure’ that they could credibly provide evidence of control effectiveness if challenged by the FCA. - 57% state they are ‘fairly confident but gaps remain’. **Number of professionals polled: 410** Source: Elephants Don’t Forget Webinar, ‘FCA Enforcement Is Changing: How Ready Is Your Firm?’, November 2025. Poll results based on 410 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/fca-enforcement-is-changing-how-ready-is-your-firm/) [Access paper](https://www.elephantsdontforget.com/resources/fca-enforcement-staying-ahead-of-regulatory-expectations-in-2026/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") September 2025 Focus Area: Business Change Key Challenge: Turning customer feedback into meaningful business change Findings & Industry sentiment: In rank order, 536 senior financial services professionals state that the top five challenges in turning customer feedback into meaningful business change are as follows - **1(Lead Answer)**  Cultural resistance: Staff and leadership don’t prioritise feedback-driven change. - **2** Lack of ownership: No clear responsibility for acting on feedback. - **3** Poor follow-through: Actions are started but not sustained or embedded. - **4** Too much manual process: Time spent on activities which add no value or insight. - **5** Weak analysis: Struggle to identify real themes or root causes. **Number of professionals polled: 536** Source: Elephants Don’t Forget Webinar, ‘Consumer Duty: Driving Better Outcomes Through Customer Feedback’, September 2025. Poll results based on 536 responses. Multiple choice allowed. Rank order. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-driving-better-outcomes-through-customer-feedback/) [Access paper](https://www.elephantsdontforget.com/resources/consumer-duty-driving-better-outcomes-through-voice-of-customer-voc-feedback/) September 2025 Focus Area: Voice of Customer Key Challenge: Customer feedback processes are not yet robust enough for evidence requirements Findings & Industry sentiment: - 62% of 536 senior financial services professionals state that their customer feedback processes are ‘not yet robust enough’ to provide evidence to satisfy Consumer Duty outcome testing. - 34% state they are ‘fairly confident’. - **4%** state they are ‘very confident’. **Number of professionals polled: 536** Source: Elephants Don’t Forget Webinar, ‘Consumer Duty: Driving Better Outcomes Through Customer Feedback’, September 2025. Available here. Poll results based on 536 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-driving-better-outcomes-through-customer-feedback/) [Access paper](https://www.elephantsdontforget.com/resources/consumer-duty-driving-better-outcomes-through-voice-of-customer-voc-feedback/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") June 2025 Focus Area: Management Information (MI) Confidence Key Challenge: Monitoring outcomes & ongoing obligations Findings & Industry sentiment: - 75% of 584 senior financial services professionals stated they are "not at all, slightly, or only somewhat confident" in their ability to generate the appropriate data/MI to meet ongoing Consumer Duty obligations. **Number of professionals polled: 584** Source: Elephants Don’t Forget Webinar, ‘Consumer Duty: Test, measure and improve your approach to better customer outcomes’, June 2025. Poll results based on 584 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/consumer-duty-test-measure-and-improve-your-approach-to-better-customer-outcomes/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") May 2025 Focus Area: Vulnerable Customers Key Challenge: Confidence in frontline support capabilities Findings & Industry sentiment: - 26% of 783 senior financial services professionals state they are ‘not at all or only slightly confident’ in their frontline staff's ability to recognise and respond to vulnerability. - 69% state they are ‘fairly or predominately confident’. - 5% state they are ‘very confident’. **Number of professionals polled: 783** Source: Elephants Don’t Forget Webinar, ‘Operationalising Vulnerability: Equip Your Frontline to Identify and Support Vulnerable Customers’, May 2025. Poll results based on 783 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/operationalising-vulnerability-equip-your-frontline-to-identify-and-support-vulnerable-customers/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") April 2025 Focus Area: Data Integrity Key Challenge: Persistent data quality issues Findings & Industry sentiment: - 52% of 753 senior financial services professionals identified data quality as their primary obstacle when compiling Consumer Duty Board Reports. **Number of professionals polled: 753** Source: Elephants Don’t Forget Webinar, ‘Your 2025 Consumer Duty Report: Meeting FCA Expectations’, April 2025. Poll results based on 753 responses. Single choice allowed. [Watch webinar](https://www.elephantsdontforget.com/resources/your-2025-consumer-duty-report-meeting-fca-expectations/) ![CDi connect](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/New%20HubSpot%20Journey%20Comm%20Assets/CDi/Icons/CDi%20connect.png?width=150&height=150&name=CDi%20connect.png "CDi connect") How Consumer Duty Insight (CDi) helps **The FCA has made it clear that firms must foster a culture that aligns with continually supporting and improving their people, enabling them to make decisions that consistently benefit consumers.** Competence under the Duty is not static, nor is it a ‘once-and-done’ achievement for employees. The regulator requires firms to view competence and cultural measurement as the foundation of a robust outcome monitoring process. The challenge all firms face is how they demonstrate that the Duty is a mindset lived daily within their organisation – and how it is ‘woven into the fabric of their culture’. CDi provides a range of cross-functional benefits, supporting firms to continually embed, assess, improve, and report on Consumer Duty progression. [See how it works](https://www.elephantsdontforget.com/consumer-duty-insight/) [![EDF-Clever-Nelly-lockup-white](https://info.elephantsdontforget.com/hs-fs/hubfs/A%20-%20PD%20HubSpot%20Campaign%20Images/EDF%20LOGO/EDF-Clever-Nelly-lockup-white.png?width=250&height=45&name=EDF-Clever-Nelly-lockup-white.png "EDF-Clever-Nelly-lockup-white")](https://www.elephantsdontforget.com/) [Privacy Policy](https://www.elephantsdontforget.com/privacy/)