Using The Consumer Duty as an opportunity to drive organisational change in the insurance industry through learning and development


The pace of change in the insurance industry over the last few years has seen a step-shift in how firms approach learning and development. It’s no longer a nice to have and, with the IDD, regulated firms have had to consider how they make learning and development more accessible to their employees. With the rapid pace of technological advancements both during and post-pandemic, organisations have had to think more about talent management to recruit and retain staff, better manage their customers’ expectations and to develop new skills in the workforce to cope with and manage this change.

Regulated firms can no longer rely on experience alone. As an industry we have matured, and we are seeing demand for new skills and knowledge that is being driven by regulation, generational succession, and consumer demand. Now more than ever, learning and development needs a long-term continual effort from employees, so it’s important for employers to provide the opportunities for staff to go beyond the basics required for the job role alone.

If Senior Managers do not lead the way, then how will those who follow them be expected to buy into the necessary changes?

As the implementation deadline for the Consumer Duty approaches, there is even more urgency for firms involved in insurance distribution to evolve their strategies for learning and development at all levels within the business. Central to this is the necessity to not treat the customer as a number, but rather as an individual with their own needs and protection requirements that must be managed on a case-by-case basis. This is not an easy task, and it requires a whole new set of skills that do not simply rely on technical expertise. This is what drives our professional standards.

A focus on culture

The Consumer Duty will require a significant shift in culture and behaviour for all insurance intermediaries. Senior Management will need to drive the changes forward and set the tone from the top, embedding the cultural shift within the firm’s values and behaviours. If Senior Managers do not lead the way, then how will those who follow them be expected to buy into the necessary changes? The adage, “if I didn’t treat my customers fairly then I wouldn’t have any customers left” isn’t going to wash any more. The FCA expects us to show how we are raising the bar. We are seeing many firms, particularly the smaller ones, struggling with defining what culture and values mean to them, so don’t feel alone and seek help if you need it.

A focus on the whole distribution chain

Learning and development programmes must be established and measured for all relevant stakeholders including SMFs, management, customer facing and non-customer facing staff, third parties, and there should be a particular focus on those Principal firms who have Appointed Representatives. Everyone needs to understand not only the significance of the new requirements, but also their own involvement in the implementation of new processes and their role in supporting the customer journey.

A focus on learning and development

We think it’s important that firms start to change how they think about training. Any cultural change should consider the subtle benefits gained from embedding a learning and development mindset into the business. Training should form one part of this. As well as delivering training in line with the Consumer Duty that includes guidelines, best practices, case studies and briefing updates from the regulator, firms should also now consider providing opportunities to promote lifelong learning for staff that incorporates an emphasis on developing business and soft skills training, management and leadership development, ongoing coaching, and career development.

As a new requirement from the FCA, Consumer Duty is going to take time to bed in and get right. Firms will need to practice test and learn models of working, with continuous feedback loops within the business that will help them fine tune their approach to getting things right. Learning from what works and more importantly what doesn’t work is crucial to reducing customer harm and staff will need to have the skills and confidence to support this.

Firms should provide opportunities for staff to develop these new skills and any training or learning and development should be delivered in a format that is accessible, engaging and interactive. Consider a range of methods, including in-person workshops, online courses, webinars, providing reading material and hosting discussions as part of a blended learning approach. This will help employees develop a greater understanding of the Duty with a more rounded sense of ownership of their own personal development to recognise areas where customers may need additional support to ensure that the products and services they buy meet their needs.

As part of your test and learn modelling, ensure that the business is gathering regular feedback from customers, look at your complaints and claims data, and monitor the outcomes that the business has set. Discuss them within the organisation at all levels, and make the necessary changes quickly and effectively.

By engaging your staff in this process and offering the opportunities for learning and development, you will enhance the value that you can offer your customers, and also ensure that your staff have a sense of purpose in their roles, a clear line of sight for future career development within the firm, and a more cost-effective way for the business to manage its own talent.


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Tom Wood UKGI is one of the leading compliance consultancies to the general insurance, consumer credit and claims management sectors. We can help your business succeed, with the clear expert compliance advice you need in a complex and ever-changing regulatory environment. We provide a broad range of consultancy services that can be tailored to meet the specific requirements of your business and staff, including CII-accredited compliance workshops and webinars. Ensuring you adhere to the latest rules and regulatory best practice can be a complex and time-consuming undertaking for any general insurance business. It can sometimes feel like a burden, distracting you from your core focus on looking after clients. An experienced specialist consultancy like UKGI can lighten the load. We have over 15 years’ regulatory and compliance consultancy experience. So when you work with UKGI, you can rest assured you’re in safe and expert hands.

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