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2026 has seen positive progress. Most insurers understand the legislation and what needs to change, although many intermediaries are still working this through. The challenge for insurers now is delivering those changes consistently across underwriting, distribution including intermediaries, claims, servicing, training, quality assurance and monitoring.
The next year will be consumed by practical delivery with key priorities for 2027 including:
This is where regulatory change programmes become significantly more complex. Updating a policy or process is relatively straightforward. Embedding it across an organisation is considerably harder yet this is where success or failure is ultimately determined.
Customers will not experience CoIA through legislation. They will experience it through the questions they are asked, the information they receive, the advice and support provided by intermediaries, the claims they make, and the decisions insurers take. Success depends on these changes being delivered consistently in day-to-day operations.
From an implementation perspective, my top three tips are to:
Commencement is a critical milestone, but not the finish line. The real measure of success will be whether insurers can demonstrate that CoIA is operating effectively in practice.
By 2028, compliance programmes will be complete, training will have been delivered, new policies, processes and controls will be operating, Boards will be asking questions, and the regulator will be monitoring compliance. The focus shifts from implementation to evidence.
These are fundamentally questions about embedment and past experience tells us that embedment is the most difficult phase of any major regulatory reform.
As an aside, an area where significant uncertainty remains is the regulations relating to standard-form notifications of disclosure duties. This area is unresolved which creates understandable challenges for implementation teams as we are reaching the point where design decisions need to become operational decisions. Insurers and intermediaries may need to make assumptions, build interim solutions, or leave capacity for future change.
None of these approaches are ideal. While there is still time before commencement, greater certainty on the outstanding regulations would help reduce implementation risk and allow organisations to focus on delivery rather than contingency planning.
Insurers appear reasonably well positioned from a planning and design perspective. The focus for 2027 is delivery: embedding changes into everyday operations and establishing the evidence needed to demonstrate ongoing compliance. By 2028, attention will shift from implementation to proof that frameworks, processes and controls are working as intended.
If you would like to compare notes on CoIA implementation, I would love to chat. Feel free to reach out.
2026 has seen positive progress. Most insurers understand the legislation and what needs to change, although many intermediaries are still working this through. The challenge for insurers now is delivering those changes consistently across underwriting, distribution including intermediaries, claims, servicing, training, quality assurance and monitoring.
The next year will be consumed by practical delivery with key priorities for 2027 including:
This is where regulatory change programmes become significantly more complex. Updating a policy or process is relatively straightforward. Embedding it across an organisation is considerably harder yet this is where success or failure is ultimately determined.
Customers will not experience CoIA through legislation. They will experience it through the questions they are asked, the information they receive, the advice and support provided by intermediaries, the claims they make, and the decisions insurers take. Success depends on these changes being delivered consistently in day-to-day operations.
From an implementation perspective, my top three tips are to:
Commencement is a critical milestone, but not the finish line. The real measure of success will be whether insurers can demonstrate that CoIA is operating effectively in practice.
By 2028, compliance programmes will be complete, training will have been delivered, new policies, processes and controls will be operating, Boards will be asking questions, and the regulator will be monitoring compliance. The focus shifts from implementation to evidence.
These are fundamentally questions about embedment and past experience tells us that embedment is the most difficult phase of any major regulatory reform.
As an aside, an area where significant uncertainty remains is the regulations relating to standard-form notifications of disclosure duties. This area is unresolved which creates understandable challenges for implementation teams as we are reaching the point where design decisions need to become operational decisions. Insurers and intermediaries may need to make assumptions, build interim solutions, or leave capacity for future change.
None of these approaches are ideal. While there is still time before commencement, greater certainty on the outstanding regulations would help reduce implementation risk and allow organisations to focus on delivery rather than contingency planning.
Insurers appear reasonably well positioned from a planning and design perspective. The focus for 2027 is delivery: embedding changes into everyday operations and establishing the evidence needed to demonstrate ongoing compliance. By 2028, attention will shift from implementation to proof that frameworks, processes and controls are working as intended.
If you would like to compare notes on CoIA implementation, I would love to chat. Feel free to reach out.
