REG Reviews

REG Reviews – November 2026

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Welcome to your November Edition of REG Reviews!

REGULATORY

The FCA Wants to Scrap the Certification Regime

The FCA has put the Certification Regime on the table for removal. CP26/37, the second phase of its SM&CR review, proposes retiring the Directory of certified and assessed persons, ending ongoing submission of Statements of Responsibilities and Management Responsibilities Maps, removing certain Senior Management Functions, raising the thresholds that pull firms into the Enhanced regime, and raising breach reporting thresholds. Comments close on 22 January 2027 and the FCA expects a Policy Statement in the first half of that year.

For a broker or MGA, the Certification Regime has meant an annual exercise in assessing fitness and propriety across everyone performing a certification function, issuing certificates, and keeping the Directory current. Losing all three removes a recurring administrative burden that has never sat comfortably in firms with small HR functions and a lot of client-facing staff.

Read the proposal carefully before celebrating. The FCA is proposing to remove the machinery, and nothing in the paper removes a firm’s obligation to make sure the people giving advice and handling client money are competent to do it. The Conduct Rules stay. The Threshold Conditions stay. Supervisors will still ask how a firm satisfied itself that a particular account executive was fit for the role, and a firm that responds by saying the certification process went away will have a short conversation.

The timing deserves a mention. The FCA extended the Conduct Rules on 1 September 2026 to bring serious bullying, harassment and violence formally within scope, and followed with a multi-firm review of non-financial misconduct at wholesale brokers in October. Firms are therefore being asked to document more about individual behaviour at the same moment the regulator proposes to dismantle the annual process most of them built to document individual competence. Those two things need to meet somewhere in the middle, and the firms that think about where before January will write a better consultation response.

Compliance teams have a practical question to settle in the meantime. If the Directory disappears, how will your firm evidence to a client, a capacity provider or a prospective employer that an individual was certified and when? The public register has been doing that work quietly for years. Something will need to replace it internally, and building that record is easier while the current one still exists.

TECHNOLOGY

An AI Agent That Buys and Changes Cover, Not Just Talks About It

1st Central has launched Motivo, a motor proposition built around an AI agent that carries out tasks on the customer’s behalf. Policy changes and payment management happen inside the conversation rather than through a form or a phone call, handled by an assistant the group has named KAI. It launched exclusively on Confused.com, built with Microsoft AI and cloud technology on top of 1st Central’s own policy administration platform.

Previous UK insurance AI has advised, answered and routed. This one transacts. A customer changing an address, adding a named driver or moving a payment date gives an instruction and the agent executes it. Chief executive Michael Lee has put the saving at around 40% of the time a customer spends managing their insurance.

Three consequences follow for brokers watching from the commercial side of the market.

The first is a cost benchmark. Mid-term adjustments, payment queries and address changes make up a large share of personal lines servicing volume and almost none of its margin. A competitor processing that work without a human touching it resets what the market considers a reasonable cost to serve, and the comparison will reach commercial lines eventually.

The second is the service proposition. Brokers have long defended their position on the strength of being reachable when something goes wrong. An agent available at two in the morning that completes the task in ninety seconds answers a different need, and a decent number of clients prefer it for routine work. The broker argument holds for the complicated conversation and gets weaker for the simple one.

The third sits with compliance. An AI agent making changes to a live policy creates an audit question about who authorised what and on what basis, and a Consumer Duty question about whether a customer who instructs an agent has understood the consequence for cover. The FCA named box-ticking human review as poor practice in its October paper on AI, which suggests it will look closely at how oversight works in propositions like this one.

Worth watching over the next year: whether Motivo stays confined to servicing or extends into claims, and whether a broker platform offers anything comparable. The software houses have been promising agentic capability for a while and the carriers are shipping it first.

FINANCE

Eleven Quarters of Falling Commercial Rates

Marsh’s latest global index puts UK commercial insurance rates down 8% in the third quarter of 2026, matching the fall in each of the previous two quarters and running ahead of the 5% global decline. Property led the way at minus 11%, helped by a quiet catastrophe season. Cyber fell 7%, a little faster than the 5% of the second quarter. Every UK line declined.

The eleventh consecutive quarterly fall takes the soft market close to its third birthday, and the compounding is what hurts. A commercial book that has not won new business since 2023 is now earning commission on a materially smaller premium base for the same amount of work, and in many cases more work, since client expectations have not softened alongside the rates.

Client conversations get easier in a soft market and broker economics get harder. Those two facts pull in opposite directions, and the firms handling it well have stopped treating the rate environment as weather to be waited out. The ones struggling are the ones whose growth over the past six years came from rate rather than from winning accounts.

Three responses are visible across the market. Some brokers are converting savings into cover, using the rate reduction to fund higher limits, broader wordings or additional lines rather than letting the client bank the difference. Cyber is the obvious candidate, with rates down and limits mostly static. Others are moving towards fee income on larger accounts, which decouples what the broker earns from what the market charges. And a good many are buying, which is what the M&A figures show: UK distribution deal values passed £3bn this year on 22% fewer transactions than last.

For MGAs the pressure arrives in a different form. A capacity provider working to a deteriorating loss ratio will question rate adequacy harder at business planning, and an MGA that grew its top line through a softening market needs an answer about where that growth came from. Volume written at inadequate rate is visible in the numbers eventually, and 2027 planning season is where the questions start.

Marsh’s data covers the large and mid-corporate end of the market, so regional commercial books may be seeing something gentler. The direction is the same.

CYBER

An AI Found the Flaw, and Thousands of Websites Went Dark

The NCSC issued an alert on two critical vulnerabilities in PHP, CVE-2026-109618 and CVE-2026-109619, warning that under certain conditions the flaw could be exploited to achieve unauthenticated remote code execution. Its advice was to update immediately, and to take systems offline where a firm could not apply the update or a temporary mitigation in time. A good many organisations chose the second option. Oxford City Council and the City of Edinburgh Council pulled their websites down. The Office for Budget Responsibility did the same.

Cloudflare’s chief executive reported thousands of attempts to exploit the flaw in the ten hours before it was announced publicly, rising to millions once the news broke.

The detail that makes this different from an ordinary patch cycle is where the flaw came from. A researcher found it in August using an advanced OpenAI model. The vulnerability had presumably been sitting in widely deployed code for a long time, invisible to the people maintaining it, until a machine read the code and spotted what humans had missed.

Two things follow for anyone writing or buying cyber cover.

The aggregation question is the larger one. PHP runs underneath an enormous share of the web, including the content management systems most SMEs use without knowing the name of the technology involved. A cyber portfolio with a few hundred SME insureds almost certainly has PHP under a large proportion of them, and nobody is tracking that the way the market tracks cloud or endpoint concentration. One dependency, simultaneous exposure, and no way to diversify out of it after the fact.

The second is timing. Underwriters have long assumed a window between a vulnerability becoming known and criminals operationalising it, which is the window a reasonable patching policy is built to fit inside. Millions of exploit attempts within hours of disclosure compresses it to something close to nothing. A control question that asks whether a client patches critical vulnerabilities within thirty days is asking about a timescale that no longer matches the threat.

Brokers have a useful conversation available on the back of this. Ask a commercial client who maintains their website, how quickly that supplier patches, and what the contract says about it. Very few will know.

ESG

Flood Resilience Is About to Become Something You Can Prove

The Government and Flood Re are piloting Flood Performance Certificates, which would give a property a Flood Performance Rating broken into categories such as exposure, characteristics and resistance. The stated goal is for the certificate to become a trusted source of information in the way an Energy Performance Certificate is for energy. Piloting begins this year, with more pilots running through 2027 and beyond.

The problem this addresses has frustrated brokers for years. A homeowner in a flood postcode who spends several thousand pounds on barriers, non-return valves, raised electrics and water-resilient flooring has no way of proving any of it to an underwriter. The work is invisible at quote. Two houses on the same street, one hardened and one untouched, present identically to a rating engine that sees a postcode and a flood model. Clients have asked brokers what resilience work would do to their premium, and the honest answer has been very little, because nothing records it.

A certificate changes what the broker can do with that question. Resilience spending becomes evidence instead of goodwill, and a conversation about barriers and flooring becomes a conversation about a rating that insurers and lenders can read.

Hold the enthusiasm at the right level for now. The gov.uk announcement states that the final design, content and format are still being developed, so nobody can yet say what an FPC will look like or how underwriters will use it. Flood Re has separately acquired BeFloodReady, the former Environment Agency Pathfinder project, and intends to build it into a national hub for flood advice and resilience supplier connections, which looks like the infrastructure an FPC scheme would need underneath it.

Two things are worth doing before the pilots report. Brokers with household books in flood-exposed areas can start identifying which clients have already carried out resilience work, since those clients will want certificates early and will remember who told them. And commercial property teams should watch whether this extends beyond residential, because the same evidential gap exists for small commercial premises and nothing in the announcement rules it out.

Flood Re winds down in 2039. Anything that moves the market from subsidising flood risk towards reducing it deserves attention now rather than in 2038.

REGULATORY

Why the FCA Wants Firms to Move Beyond Tickbox Compliance

FCA chief executive Nikhil Rathi has called on UK financial services firms to move away from tick-box compliance, arguing that excessive data collection and complex processes are creating unnecessary burdens.

He believes firms should use their resources more effectively to tackle financial crime and that the FCA will take a more proportionate approach to supervision, focusing its attention on areas where the risk of harm is greatest.

Rathi added that firms must also address repetitive compliance processes, including overlapping assurance exercises, risk reports and internal audits, some of which are driven by regulation and others by commercial decisions.

FCA deputy chief executive Sarah Pritchard will work with the sector to identify and reduce unnecessary requirements, encouraging boards to reconsider whether the traditional three lines of defence model remains appropriate.

Rathi highlighted the need for firms to move beyond traditional KYC checks to identify actual money laundering, as the FCA prepares to take on AML supervision of more than 60,000 professional services businesses by 2028.

New COO Johan Sekora will lead efforts to strengthen intelligence-led approaches, while existing KYC, transaction and sanctions monitoring data will continue to play an important role in detecting financial crime.

He said firms must better connect existing customer data to identify potential risks. The FCA also plans to use AI to analyse regulatory information and flag concerns, allowing supervisors to focus on complex decisions involving market manipulation and systemic risks.

REG UPDATES

Are You PS26/2 Ready? Take Our New Readiness Check to Find Out

In March 2026, the FCA published PS26/2, its new rules on how firms report and oversee material third-party arrangements. They come into force on 18 March 2027, and for many firms the hard part will not be understanding the rules but proving they can meet them.

The scope is wider than before. Oversight used to focus on outsourcing, but PS26/2 captures any material third-party arrangement, including software, cloud, group services and, for insurers, delegated underwriting. In-scope carriers must notify the FCA about new or significantly changed arrangements and submit an annual register, with data accurate as at 31 December and a 90-day window to submit once the FCA invites it.

The impact does not stop with carriers. MGAs, coverholders and brokers with delegated authority may not be directly in scope, yet the carriers they write for may still need their due diligence, subcontractor and resilience information. In effect, you could become someone else’s audit evidence.

That is why we have built the PS26/2 Readiness Check. It takes about five minutes and asks 22 questions: two about your firm and 20 multiple-choice questions across four themes, covering scope and planning, third parties and materiality, your register and notifications, and due diligence and governance.

Every question explains what the FCA expects and where in the rules it comes from.

At the end, you receive:

  • A readiness score out of 60, with a band from Getting started to PS26/2 ready
  • A breakdown across the four themes, showing where you are strong and where gaps sit
  • Priority actions for your weakest areas ahead of March 2027

The check adapts to where you sit in the distribution chain, so it is useful for compliance and risk leaders, MGA founders and operations teams, carrier distribution teams and broker management alike.

Why now? Building a reliable third-party register takes time. Firms still relying on spreadsheets and email trails may struggle to produce dated risk assessments, due diligence outcomes and governance sign-off on request.

The earlier you know where the gaps are, the less you will be doing against the clock.

The check is a guide to help you prioritise, not legal or regulatory advice. It does not cover operational incident reporting, and your firm remains responsible for confirming its own scope and materiality assessments.

Take the PS26/2 Readiness Check

TECHNOLOGY

Underwriting Reimagined: What AI Means for Insurers and MGAs

As AI adoption in underwriting moves beyond the pilot stage, insurers are increasingly focused on scaling its use and measuring its impact. Attention is shifting towards key challenges such as data quality, governance, technology investment and workforce changes, with AI orchestration emerging as a central part of successful integration.

Underwriting teams are increasingly using orchestration tools to coordinate tasks between AI agents and human employees.

Modern underwriting workbenches are evolving into platforms that manage these workflows, improve data reliability and ensure people focus on decisions requiring human expertise, with growing confidence that this approach can improve efficiency and profitability.

AI adoption is expected to deliver significant commercial benefits, with 53% of commercial P&C insurers anticipating revenue growth of 11–15% over two years.

While some industry leaders question whether AI will genuinely reduce costs, examples such as Markel demonstrate its potential, with an AI-powered underwriting tool reportedly increasing productivity by 300% and generating $30m in new business, according to Oxbow Partners.

Ultimately, AI is enhancing underwriting expertise by automating routine tasks and providing insights that support better risk assessment, pricing decisions and portfolio management.

Industry leaders agree that human judgement remains essential to underwriting, particularly in specialty insurance, where experience, broker relationships and negotiation play a key role.

Markel International’s CUO, Tom Hillier, stresses that technology cannot fully replicate the conversations needed to understand clients and assess risk.

Similarly, Apollo’s CUO, James Slaughter, highlights the importance of human oversight in AI-driven decisions, arguing that trust in these systems must be built through human involvement and engagement with data.

Chris Mullan, head of data and AI at CFC highlights that AI cannot replicate the market knowledge, negotiation skills and broker relationships that human underwriters bring to decision-making.

Similarly, Elizabeth Wooliston, chief of markets at Artificial, emphasises the importance of commercial judgement, contextual understanding and human connection, particularly in complex casualty risks.

William Harnett, head of product strategy at Send also stresses the need for experienced underwriters to challenge AI recommendations and identify less obvious risks that automated systems may overlook.

AI can also improve transparency and help insurers identify bias in underwriting decisions. However, several experts stress that consistent outcomes do not always mean accurate pricing, making human judgement and oversight essential.

They highlight the need for strong AI governance to prevent bias, ensure accuracy and maintain accountability in underwriting decisions.

Allianz Trade’s Vik Vijai and Sollers Consulting’s Jakub Śliwiński stress the importance of transparency, explainability and ongoing human oversight, while Send’s William Harnett warns that AI models can reinforce existing biases.

Pegasystems’ Manoj Pant adds that reliable AI also depends on connecting, standardising and enriching data from multiple sources.

Finally, as AI continues to reshape underwriting roles, it will free up time for stronger broker relationships and staff development while requiring underwriters to build greater data literacy, analytical skills and confidence in challenging AI-driven insights.

ESG

Culture is Moving Faster than Regulation, Warns Lady Mayor

The Lady Mayor of the City of London, Dame Susan Langley, has warned that some firms are interpreting regulatory rules too cautiously, according to Insurance Post.

Speaking at the Chartered Insurance Institute’s Shaping the Future of Insurance conference on 1 October, she said the UK’s structured regulatory environment is a major strength, but must be flexible enough to respond to fast-moving world events, with six-month reviews no longer fit for purpose.

Langley, who is also non-executive chair of Gallagher, described the challenge as cultural as much as legal. Firms, she said, lean towards caution because it shields them from financial and reputational damage, including scrutiny on social media.

She added that regulation tends to accumulate over time, with each review adding something new, until it risks constraining the kind of thinking today’s uncertain environment demands.

She was clear she was not calling for rules to be scrapped. Instead, she urged leaders to be braver and act faster, warning that slow responses can lead to poor customer outcomes, while still knowing where the red lines sit.

The bigger picture: Being braver is easier said than done, and it only works when firms have clear evidence and strong controls behind each decision, otherwise caution will always feel like the safer option.

REG UPDATES

REG Runs with Insurtech Run Club

REG Technologies is proud to have sponsored the latest Insurtech Run Club event, which drew the club’s largest attendance to date.

Insurtech Run Club brings together professionals from across the insurance and technology sectors for a 5k run through the City of London, followed by an informal networking session. The format offers a valuable opportunity for industry colleagues to connect outside the usual setting of meetings and conferences, and it has quickly become a fixture in the market’s calendar.

We would like to extend our thanks to organisers Nick Goodwin, Elliott Green and Harry Moore for welcoming REG as a sponsor. Their commitment to building an inclusive, well-run community has clearly resonated, and the record turnout reflects the momentum the club has built.

As part of our sponsorship, REG provided branded t-shirts and socks for participants. The shirts carried the message “good partners keep you moving,” a principle that sits at the heart of how we work. Insurance is a collaborative industry, and progress depends on partners who can respond quickly, adapt to changing conditions and support clients through periods of growth and pressure. That is the standard REG holds itself to, and we were pleased to see it represented across the route.

The response to the merchandise was excellent, and the sight of REG colours moving through the City made for a memorable evening. We are grateful to every participant who took part, whether setting a new personal best or simply enjoying the run alongside peers.

Supporting initiatives like this is something we intend to do on a REGular basis. Events that bring the market together, encourage wellbeing and strengthen professional relationships align closely with our values, and we look forward to continuing our involvement.

Our thanks again to the organisers and everyone who attended. We will REGroup at the starting line for the next one.

CYBER

When the Customer Sends the Money: The Cyber Cover Gap

Impersonation scams are fast becoming 2026’s defining fraud threat, and many standard policies may not respond to them, according to Insurance Business.

Allstate Identity Protection data released on 29 October shows these scams made up almost 60% of its cases between January and September.

In “fake-and-take” schemes, criminals pose as a bank, government body, delivery firm or relative to persuade victims to send the money themselves.

That distinction matters for coverage. Allstate found over 90% of its 2026 scam cases involved payment routes such as cryptocurrency, wire transfers, gift cards and peer-to-peer apps, and nearly 75% began with a phone call.

The US Federal Trade Commission reported that Americans lost $3.5bn to imposter scams in 2025, almost triple the 2020 figure, while Pindrop’s 2025 report recorded a 475% rise in synthetic voice fraud at insurers.

The core issue is the voluntary parting exclusion in many crime and cyber policies, which removes cover where the policyholder authorised the payment, even if deceived. Kareen Boyadjian, vice president of personal and healthcare cyber underwriting at CPLG told Insurance Business that standard wording is no longer enough, with voluntary wire transfer fraud now a major gap for high-net-worth clients.

Allstate has responded with a scam protection benefit offering up to $50,000 a year in reimbursement, signalling a market shift towards covering payments made by the victim.

Worth noting: this is a US story, but UK brokers may want to check how their clients’ policies treat payments made under deception.

REGULATORY

Why the FCA is Concerned About Firms’ Reliance on AI Providers

The FCA is cautioning firms against leaning too heavily on single AI suppliers, according to Insurance Post. Its new report, published on 19 October, sets out examples of strong and weak AI practice to help firms adopt the technology sensibly, and builds on July’s Mills Review.

The FCA’s Jessica Rusu observed that consumers are already using chatbots such as ChatGPT, Gemini and Claude to find financial information. That could open up access, but may also muddy the distinction between regulated and unregulated activity.

The regulator wants AI providers to display clear, consistent warnings about the limits of their financial output, and will extend its existing initiatives rather than build the new public-interest tool the Mills Review suggested.

On supplier risk, the FCA stressed that handing AI work to a third party does not hand over responsibility, Insurance Post reported.

Stronger firms built systems able to swap between providers, brought legal, compliance and risk colleagues into buying decisions, kept a record of their AI uses and suppliers, and prepared for supplier disruption.

Weaker firms took vendor claims at face value and had no fallback if a model became unsuitable or unavailable.

The report also expects firms to settle on the customer outcome they want before picking a tool, check for unfair results across customer groups, test whether customers actually understand AI outputs, and support vulnerable people, including offering human-led help for simple tasks. Smaller firms are held to the same principles, with oversight scaled to the risk involved.
Reaction was mixed. Michael Sicsic of Sicsic Advisory welcomed the practical examples but felt many were light on detail, noting that pricing, underwriting and fair value were absent.

He advised insurers, MGAs and brokers to trace who is responsible for each AI tool along their chain. Cormac Bradley of Broadstone said the findings show AI offers no exemption from regulation.

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