Consumer Duty & Technology Partners: Changing The Definition of Excellence for Delegated Authority?

What does an outstanding Technology Partner for the Delegated Authority ecosystem look like in 2022/23? In this article, Shân Millie proposes that the new FCA rules on Consumer Duty’s create a fundamental change for all providers, whether the DA client is directly SME/Consumer-facing (B2C, D2C), or whether the impact of their activities is at second-hand or more (e.g. B2B2C). This creates new opportunities for differentiation and competitive advantage for the progressive Tech Partner.

The Stand-out Tech Partner: it’s being great at Innovation, isn’t it?

Well, yes. But what does ‘Innovation’ mean in the context of the new environment created by FCA Consumer Duty Rules, and as we look towards the end of 2022 and beyond to  2023? Any definition of ‘Innovation’ must now embrace how the firm is going to re-engineer its operations and culture to meet the requirements of Consumer Duty, quicker, better and more cost-effectively. (1) How many Tech Providers are currently talking about how their product and service addresses this Innovation need?

For the firm, Consumer Duty requires a fundamental shift in focus – from rules-based to outcomes-based operations — with the highest priority on verifiably positive impacts for the (SME and individual consumer) Customer.  For the majority of firms (large and small) with whom I’m speaking, this change in regulatory approach to ‘show me, don’t tell me’ engenders a business-wide Transformation project with impacts on every part of the Value Chain, and on every function within the firm.

View from the Firm: Consumer Duty as an unprecedented spur to innovation

For some, it’s even more than that: it’s the most significant imperative for operational change in at least a decade, if not longer.

The essential but often ‘unsexy’ long road to fixing e.g. Bordereaux, and half-done or non-existent post-M&A integration, continues. But as firms draw up their Consumer Duty Board Implementation plans (due October 31 2022) and work out how they will meet the 2023 deadlines, programmes in RPA/IA, CX, Data enrichment and much else typically labelled ‘Transformation’ – are also being drawn into the Consumer Duty ambit.

Consumer Duty demands a step-change in Management Information (MI), and a new level of structured coordination of those dynamic, often silo’ed internal functions, and the web of external relationships and partnerships, that are the lifeblood of Delegated Authority. Technological and Data capabilities obviously sit at the heart of this – whether you are sitting in the DA Principal chair, or around the table as the MGA (especially if you’re a co-manufacturer).

So clearly there’s a great opportunity for the progressive Technology Provider to get ahead of the pack. Here are three examples of new opportunities for differentiation.

  1. MI & Workflow Needs

Tech Solution Providers have the opportunity to materially and specifically help here.

PROD 4 (FCA product governance and fair value rules), for instance, creates all kinds of functionality needs for Brokers and MGAs that will also help Compliance with Outcome 1 (Products and Service) and Outcome 2 (Price and Value). In practice, revamped systems could be key in providing the means for:

  • MGAs and Insurers to communicate and share Fair Value assessments to Brokers. (PROD 4.2.29 R)
  • product-specific training to Brokers, and that is regularly updated (PROD 4.2.33 R)
  • creating and storing the roles and responsibilities between parties (PROD 4.2.14 R)


  1. AI: something new to talk about

And it’s already started, although it’s instructive that the vast majority of this activity is coming from providers outside the traditional Insurance specialist community. Some AI specialists have quickly cottoned-on to the range of hard-core information, communication and data collection issues and are quickly adding a Consumer Duty element into their sales deck. There will be a lot more of this “AI as the fourth line of defence” or “machine line of defence” narrative to come, as well as AI being the answer to otherwise ‘uneconomic’ Quality Assurance needs in the firm.

  1. Enabling an appetite for the firm to lead on – not just comply with – Consumer Duty

Some MGAs are not simply intent on the best and most efficient re-tooling of operations and culture to meet the new standard.  There are a number of players of various sizes seeing huge advantage in setting the pace and taking a leadership position that directly powers their GWP growth.  And in a good number of these firms, Governance and Compliance experts are leading the charge, working hand in hand with Transformation, Digitalisation and Innovation functional heads. There’s a huge amount of energy in these teams!

I’ve spent a lot of time over the 16 years’ or so obsessing about Insurance from the ‘outside-in’, investigating what it takes to make Tech- and data-enabled Innovation ‘stick’: in many ways it feels like Digitalisation finally has a purpose that insiders can get their hands (and heads!) around: the Customer, and specifically, Consumer Duty.

Final Thought

We’ve all got used to ‘Technology’ and ‘Data’ being interchangeable with ‘Innovation’ so most providers would want to dial up their ability to enable, fast-track, accelerate Innovation. However, the ability to deliver on new Consumer Duty impacts the in-depth understanding to help DA firms meet their ‘leadership in Customer’ aspirations, and the vision to imagine how this translates into Next Gen Tech services and products could well be the new benchmarks for success for ‘excellent’ Tech Partners for DA.

Shân is GK’s expert in FinTech & Digitalisation and Innovation & Customer Lead. She is a subject matter expert in AI/ML & Digital Governance and ESG impacts on firms, leaders & their Customer. Her specialism include: strategic advisory; business & market development; applied customer insights e.g. value proposition development; Corporate StoryTelling.

(1) GreenKite has produced a number of useful resources on Consumer Duty. Check them out here.

GK Service Propositions

GreenKite Digital Promotions HealthCheck

GK & Guest Blogs

GK Blog—Consumer Duty Impacts: the need-to-know & non-negotiable

GK Blog – Consumer Duty: Innovation Blocker or Driver?

GK Blog: #FinTikTok works: so joined-up, compliant Digital Promotions is the ‘new’ Digitalisation

GK Vlog – Digital Promotions – The New Compliance ‘Must-Do’?

Guest Blog – Customer Duty – Opportunity to Repair Trust

Guest Blog – It’s all about Trust

GK webinars 

GreenKite Webinar – Consumer Duty: Innovation Blocker or Driver?








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