INSURANCE INSIGHTS

THE WHO2 GLOBAL VIEW Non financial misconduct has gone from being viewed as “an HR issue” to becoming a boardroom conversation very quickly. With the FCA’s updated expectations coming into focus in September 2026, the question is becoming: WHAT ARE FIRMS ACTUALLY DOING ABOUT IT? If we’re honest, many organisations are probably still working out where ownership sits. Is it Compliance? HR? Risk? SMCR? Conduct? Culture? The reality is that it is likely a combination of all of th

THE WHO2 GLOBAL VIEW The FCA’s AI Live Testing initiative is worth paying attention to. Not because it gives the market permission to use AI. Because it starts to show what “good” looks like when AI is already live in real insurance workflows. From what Avantia shared following its involvement, the message feels pretty clear: The FCA is not saying “don’t use AI”. It is saying: Use it, but prove you are in control of it. That is the important bit. The focus does not seem to be

THE WHO2 GLOBAL VIEW The FCA has updated its complaints reporting guidance and this is one firms should not leave until late 2026. From 1 January 2027, affected FCA-authorised firms will move to a single, unified complaints return, replacing five existing complaints returns across DISP, Consumer Credit, Funeral Plans, Claims Management Companies, and Payment Services / E-money. For insurance firms, brokers, intermediaries and wider retail financial services businesses, the ke

THE WHO2 GLOBAL VIEW Picture the scene. You own a shop. Every morning, you unlock the doors, switch the lights on and make sure everything is exactly where it should be. The shelves are tidy. The products are lined up perfectly. The signage looks good. Nothing is technically broken. In fact, it has looked pretty much the same for years. So, the shop floor isn’t a mess. It’s “perfect”. Or is it? Because nobody has asked whether the right products are in the right places. Nobod

THE WHO2 GLOBAL VIEW The FCA has published its latest findings on good and poor practice across products and services under Consumer Duty. And for us at WHO2, one message stands out: Having the process is not the same as proving the outcome. The FCA’s review looked at 38 firms across financial services, including insurance, and identified good practice alongside clear areas for improvement. The findings cover product design, target markets, ongoing monitoring, distribution, t

THE WHO2 GLOBAL VIEW The battle is no longer just for the quote. It is for the entire journey. For years, the relationship between insurers, brokers and price comparison platforms has been relatively clear. The insurer manufactured the product and carried the risk. The broker advised, arranged or serviced it. The aggregator helped the customer compare the market and then passed them across to somebody else to complete the purchase. That distinction is beginning to disappear.

THE WHO2 GLOBAL VIEW Insurance has outsourced for years. Technology. Claims. FNOL. Contact centres. Policy administration. Pricing capability. Add-ons. Data. Customer communications. Sometimes almost the entire proposition. And there are very good reasons for doing it. Why build something that already exists? Why employ 40 people when a specialist partner has 400? Why spend two years building infrastructure when somebody can switch it on in three months? A strong outsourced

THE WHO2 GLOBAL VIEW THERE IS A NOTICEABLE SHIFT HAPPENING INSIDE UK PERSONAL LINES BROKERS. Not a collapse. Not a crisis. But a quiet strain across operations, margins, people, and governance. Most brokers are still growing. Many are still profitable. But underneath the headline numbers, things feel harder than they should. That usually means the operating model is out of sync with the market. WHAT WE’RE SEEING ACROSS BROKERS RIGHT NOW Complexity has crept in faster than co