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After three years helping clients navigate CoFI, it’s been a refreshing challenge to turn my attention to something new.
Intuitively Contracts of Insurance felt like another sizeable change. After working with a number of clients to assess the impact on their business, I am now as convinced as ever that is the case - both in scale and in substance. Two areas in particular stand out:
The shift here is fundamental. Responsibility now sits squarely with insurers to ask the right questions and to actively assess the responses provided – rather than relying on consumers to know what they should disclose.
In practice, this will require:
The requirement to present contracts in a clear, concise and effective manner goes well beyond policy wording. Think product collateral, marketing material, and website – and with Unfair Contract Terms and Duty to Inform added in, this quickly becomes a significant exercise that demands strong coordination.
Regulatory initiatives have a bad habit of starting late and ending in a rush. That typically leads to tactical decisions, descoping and compromises creating long-term risk and friction post go-live. Starting early, with sound planning and project discipline, allows changes to land well. Noting we only have 18 months left!
I hear this a lot. We already treat customers fairly, pay claims proportionately, we void very few policies. That may be true – but where is the evidence?
The gap is often less about intent and more about oversight and assurance.
Another area where CoIA will feel very familiar to those who lived through CoFI and FAP is the renewed focus on intermediaries and third parties, and the complexity that brings.
The concepts themselves aren’t new, but CoIA sharpens the risk significantly through imputed knowledge and disclosure obligations. Information known by intermediaries may now be attributed to insurers, raising difficult questions about where knowledge sits, how it is captured, and how confidently insurers can evidentially stand behind underwriting and claims decisions.
In practice, this exposes similar challenges to those seen under CoFI/FAP: reliance on intermediated processes without clear visibility, inconsistent practices across distribution channels, and blurred accountability for customer interactions. Managing this risk effectively goes well beyond contractual wording. It requires clear role definition, robust information flows, and active oversight, assurance and training of intermediaries.
The focus is often on infrastructure (policies, procedures, systems, and controls) and misses the cultural, behavioural and competency shift required. Adding to the challenge is change fatigue. Training, awareness, explaining the why, and actively managing delivery risk are critical to making the change stick.
If you’re grappling with your organisation’s response to CoIA – or would just like to compare notes – I’d love to chat. Please feel free to reach out.
After three years helping clients navigate CoFI, it’s been a refreshing challenge to turn my attention to something new.
Intuitively Contracts of Insurance felt like another sizeable change. After working with a number of clients to assess the impact on their business, I am now as convinced as ever that is the case - both in scale and in substance. Two areas in particular stand out:
The shift here is fundamental. Responsibility now sits squarely with insurers to ask the right questions and to actively assess the responses provided – rather than relying on consumers to know what they should disclose.
In practice, this will require:
The requirement to present contracts in a clear, concise and effective manner goes well beyond policy wording. Think product collateral, marketing material, and website – and with Unfair Contract Terms and Duty to Inform added in, this quickly becomes a significant exercise that demands strong coordination.
Regulatory initiatives have a bad habit of starting late and ending in a rush. That typically leads to tactical decisions, descoping and compromises creating long-term risk and friction post go-live. Starting early, with sound planning and project discipline, allows changes to land well. Noting we only have 18 months left!
I hear this a lot. We already treat customers fairly, pay claims proportionately, we void very few policies. That may be true – but where is the evidence?
The gap is often less about intent and more about oversight and assurance.
Another area where CoIA will feel very familiar to those who lived through CoFI and FAP is the renewed focus on intermediaries and third parties, and the complexity that brings.
The concepts themselves aren’t new, but CoIA sharpens the risk significantly through imputed knowledge and disclosure obligations. Information known by intermediaries may now be attributed to insurers, raising difficult questions about where knowledge sits, how it is captured, and how confidently insurers can evidentially stand behind underwriting and claims decisions.
In practice, this exposes similar challenges to those seen under CoFI/FAP: reliance on intermediated processes without clear visibility, inconsistent practices across distribution channels, and blurred accountability for customer interactions. Managing this risk effectively goes well beyond contractual wording. It requires clear role definition, robust information flows, and active oversight, assurance and training of intermediaries.
The focus is often on infrastructure (policies, procedures, systems, and controls) and misses the cultural, behavioural and competency shift required. Adding to the challenge is change fatigue. Training, awareness, explaining the why, and actively managing delivery risk are critical to making the change stick.
If you’re grappling with your organisation’s response to CoIA – or would just like to compare notes – I’d love to chat. Please feel free to reach out.
