If organizations would be able to learn more effectively from incidents that occurred in the past, future incidents and consequential injury or damage can be prevented. To improve learning from incidents, this study aimed to identify limiting factors, i.e. the causes of the failure to effectively learn. In seven organizations focus groups were held to discuss factors that according to employees contributed to the failure to learn. By use of a model of the learning from incidents process, the steps, where difficulties for learning arose, became visible, and the causes for these difficulties could be studied. Difficulties were identified in multiple steps of the learning process, but most difficulties became visible when planning actions, which is the phase that bridges the gap from incident investigation to actions for improvement. The main causes for learning difficulties, which were identified by the participants in this study, were tightly related to the learning process, but some indirect causes – or conditions – such as lack of ownership and limitations in expertise were also mentioned. The results illustrate that there are two types of causes for the failure to effectively learn: direct causes and indirect causes, here called conditions. By actively and systematically studying learning, more conditions might be identified and indicators for a successful learning process may be determined. Studying the learning process does, however, require a shift from learning from incidents to learning to learn.