Celebrating 2 years of Consumer Duty

How Consumer Duty has changed the industry – for better or for worse – and what comes next?

It’s been two years since the implementation of Consumer Duty. This industry-disrupting regulation was introduced by the FCA to boost standards across the industry – pushing providers to prioritise and evidence positive outcomes for customers.

Consumer Duty was developed to deliver good customer outcomes in products and services, price and value, consumer understanding and consumer support.

With varying degrees of enthusiasm to outright cynicism, Consumer Duty was greeted with mixed reactions by those charged with implementing it.

Some saw it as a game changing opportunity to create a customer-centric culture, while others felt it was ‘lip-service’ that got in the way of doing their day job – a series of very expensive tick boxes that would blow over in time.

It didn’t. And it won’t.

Two years later, it’s here to stay and continue the party of putting customers first.

The good, the bad and the ugly

As with several regulatory resets over the years, implementing Consumer Duty put pressure on management time and resource – and undeniably squeezed profit margins.

But for other firms, Consumer Duty has enabled them to genuinely glow-up their client strategies with greater focus on fair pricing, clear and transparent communications and better support for vulnerable clients.

Two years on, the duty remains the regulation holy grail for insurers who stand by the mantra of doing right by customers.

Businesses thriving under Consumer Duty have gone beyond just treating customers ‘fairly’ – they place them at the centre of their business model!

Putting our clients first

At Irwell, we have embraced the opportunities presented by Consume Duty.  We have implemented several measures to align our client relationships with the duty’s best practice guidance.

Firstly, we have improved the clarity around our terms and conditions in policy wordings. For example, our LEI policy wording has been updated to emphasise that customers should seek and follow advice. We have also provided practical examples within the wording where the customer may need advice which gives added reassurance and makes the wording more relatable.

In line with the regulator’s focus on improving MI to help identify, evidence and monitor the delivery of good outcomes, we have introduced a comms monitoring and training programme and updated our processes to provide quicker claims determination – a critical element of improving the customer experience.

Consumer Duty puts greater responsibility on the whole distribution chain to share client information to ensure that products and services meet the required standards. At Irwell, our business is built on mutually beneficial and respectful partnerships, so we welcome this initiative with open underwriting and product development arms. We collaborate closely with our partners to help identify gaps in the market and policy provision to ensure that niche markets are better represented and protected.

Investing in Consumer Duty compliant procedures will continue to be a business priority as we expand our client base and product portfolio. We believe there is no better way to do business that putting clients first, last and foremost.

Can AI deliver CD fit for the future?

Love it or loathe it, Consumer Duty is here to stay – the only question is how will it evolve? The proliferation of AI appears to be taking over our industry.

The FCA has indicated it will make greater use of data analytics to drive decision making on business behaviour and monitoring compliance.  Digital solutions will also undoubtedly play a vital role in helping businesses comply with the evolving demands of Consumer Duty.

From automated compliance tools to digital platforms that enhance the customer journey, how can tech adoption help humans improve client engagement and experience?

How can insurers adopt a consumer-first approach when the de-humanised tech takeover seems unstoppable?

Can non-humans truly put humans first? Can AI really deliver consumer understanding? How can tech genuinely support vulnerable customers?

We believe it’s about striking a balance between tech and the human touch.

In the liability sector, when it comes to complex risks within a niche, non-standard or hazardous business you still need human relationships. You need the reassurance that a person with years of underwriting experience in mitigating business risk has meticulously reviewed your unique circumstances. You need common sense and pragmatic judgement that no standardised AI-driven data entry can offer.

But we recognise that AI and MI can offer invaluable insights and ongoing monitoring to support all compliance considerations and underwriting decisions.

Humans and robots need to work together to achieve the best outcomes. Let’s see what they bring to the next Consumer Duty party.

Protecting homes that make higher education possible

A level results day has arrived.

A day that will put an end to the waiting game and anxiety of ‘what next?’ A day that will open doors to dreams, degrees and university life for A level students around the country.

But will the Renters’ Rights Bill close those same doors as quickly as they opened – preventing students from being able to find accommodation in their chosen university city? There were 758,000 applications for full-time undergraduate places through UCAS last year – all who need somewhere decent and affordable to live.

But will they find their university dreams shattered – not by grades, but by a lack of somewhere to live?

Quite possibly yes.

Unless the Government U-turns on Section 8 of the Renters’ Rights Bill which will allow student landlords to regain possession of their properties at the end of each academic year.

Under the current proposal, only landlords letting HMOs would be able to regain their properties to re-let to next year’s student intake. One and two-bed student properties would be excluded – despite these smaller homes accounting for around a third of student accommodation in the UK.

Student housing crisis

Around 30% of students across the UK live in private rented accommodation that is not in purpose-built or provided by their higher education provider. Many popular university cities are already struggling to put roofs over the heads of their students – which is forcing up rents and making decent student accommodation the privilege of the wealthy.

Research reveals that 65% of students say that housing now influences where they apply to study – not just the course credentials and the city social scene! Plus, almost 50% are concerned about the current shortage of suitable accommodation which forces many to stay home under the roof – and bank of mum and dad.

Unless MPs back a key House of Lords amendment to the Bill, students could face a housing shortage and cost crisis – with those from disadvantaged backgrounds being hit hardest.  

MPs have the chance to protect the UK education system by safeguarding the provision of homes that make higher education possible for all – not just the privileged few.

For those students who will be out celebrating their A level results tonight, the 8th of September could prove to be the next big ‘results day’.

Stats source: https://www.nrla.org.uk/news/mps-must-seize-final-opportunity-to-protect-access-to-higher-education

AI and LI. Redefining H&S commercial compliance.

Workplace health and safety has always been a priority – and a thorn in the side of some high-risk sectors. The liability and legal implications for non-compliance can be at best – costly – and at worst – fatal.

But it also represents an opportunity to redefine best practice and business values.

From construction, manufacturing and warehousing to scaffolding and freight, HSE regulations are more than ticking off compliance checklists. They are instrumental to protecting employee health, safety and wellbeing, operational continuity and business reputation.

Despite years of improvements in health and safety culture within these sectors, the reality remains – business risk is evolving – not disappearing.

The stats shouldn’t add up

According to the Health & Safety Executive 124 workers and 92 members of the public were killed in work-related accidents in 2024/25 reported under RIDDOR.[1] A further 604,000 workers sustained a non-fatal injury according to self-reports from the Labour Force Survey in 2023/24. [2]

For business owners, HR and compliance professionals, these aren’t just statistics. They are people with families and friends. They are lives lost or changed irrevocably. They are a wake-up call that more needs to be done.

They are an alarm bell signalling that mature health and safety policies and outdated procedures may need a fresh pair of eyes – and liability insurance that includes a H&S review tailored to the unique business or sector risks.

Closing the gap on human error

IOSH, NEBOSH, RoSPA and RIDDOR certificates may proudly adorn your boardroom or site office walls. But no matter how robust and relevant your H&S accreditations, tiredness, distraction or unfamiliarity can all contribute to unintentional lapses that could have far-reaching consequences.

This is where AI-powered vision is changing the H&S game.

This artificial but intelligent layer of site safety provides an extra pair of eyes – monitoring that protocols are being followed, risk is being assessed – and people are playing by the rules.

AI can keep a watchful, 24/7 eye on a contractor arriving on-site for the first time or an experienced forklift operator at the end of a long shift – when you can’t.

AI enhancing HR and H&S

AI surveillance technology analyses visuals from cameras across your site. Unlike standalone, standard CCTV, these systems go beyond recording and storing footage – they interpret it – and provide real-time insights.

From monitoring noise or chemical levels to flagging dangerous machinery usage or ergonomic and PPE hazards, AI recognises unsafe behaviour and turns live data into early warnings and alerts.

It can spot concerning patterns in incident reports and monitor access to high-risk or prohibited areas and alert key personnel when company rules and H&S procedures are not being followed.

This may sound like the robots are taking over and Big Brother is watching, but this technology is about putting people first. It can be an integral component of a compliant and connected safety toolkit. But it also needs to work alongside the irreplaceable compassion, integrity and intuition of humans that no robot can deliver. Well, not yet anyway.

Futureproofing proactive prevention

AI computer vision and monitoring systems are also scalable to suit an SME single-site facility through to a large corporate with nationwide operations – or as business needs evolve.

As Artificial Intelligence continues its upwards and unstoppable trajectory in all areas of work, the applications and impact are set to reimagine workplace safety and redefine HR policies of the future.

AI-driven H&S adoption isn’t just about embracing new tech. It’s about building the foundations of a resilient, people-focused business.

It helps transition workplace safety from a boardroom burden to a company cultural strength.

Forewarned is forearmed when it comes to site safety

Companies that have rigorous H&S policies in place aren’t just compliant – they’re more productive, more trusted and therefore more attractive to employees, customers, investors and partners.

Prioritising people and workplace safety is one of the strongest signals of organisational ESG values – especially in high-risk industrial environments.

It’s a strong message that resonates in today’s world of social media naming, shaming and sharing.

Employers who invest in AI safety systems provide an extra layer of continuous security – and meaningful insights to make work environments safer. Just like our liability policies that include SafeCheck.

 SafeCheck is an on-site or online H&S review that informs businesses what they are doing well – and where and how there is room for improvement to help achieve HSE compliance.

Our liability insurance sends a clear message – this is a business that protects and values people. And that is a message worth sending.


[1] Work-related fatal injuries in Great Britain – HSE

[2] Non-fatal injuries at work in Great Britain – HSE