Sysdoc’s advice to insurers draws on 40 years of helping organisations adapt to regulatory and technology change: how you respond to CoIA will directly shape the cost, risk, and long-term value you create, making this an opportunity not to be wasted.
This article looks at the Contracts of Insurance Act 2024 through an operating model lens (process, systems, data, and people) focusing on what “reasonable” and “fair” mean in practice, not in law.
Imagine your organisation in 2027: CoIA done well means your front line operates with clarity and confidence, decisions are consistent across channels, communications are timely and clear, and information is captured with discipline. You have a clean, reliable operating model, one that not only meets CoIA expectations but gives you the clarity to adapt quickly to the next regulatory change, technology shift, AI innovation, or competitive move.
CoIA done poorly, and the opposite emerges. Inconsistent outcomes create risk, cost and rework. Teams experience change fatigue, processes fragment, and customer experience suffers. Front-line heroics become the safety net, holding things together through workarounds and escalations. It’s a familiar and expensive pattern and it doesn’t prepare you for the future.
What the Act is changing in practice
We believe the impact of CoIA will be deeper and more foundational to operations than the CoFI regulation that
has preceded it. We see this concentrating pressure in three areas:
1. Consumer disclosure requires new and more process, people and data discipline.
Consumers must take “reasonable care” not to make a misrepresentation, but the Act makes insurer behaviour relevant: how clear the questions were, what happened when answers were incomplete, and how disclosure is assessed.
How much friction are you willing to introduce into the customer experience to ensure you have sufficient information to accurately assess and underwrite the risk?
2. Information management and communication becomes a process, systems and data governance problem.
This Act elevates the criticality of disciplined data capture, assessment and traceability. If that record is patchy, your compliance risk increases, and your ability to react weakens.
How costly is it for you today to identify, retrieve, analyse and present data to customers, partners and to the regulator? And what level of confidence do you have in the integrity of that data?
3. Claim payment timeliness becomes a process, people, data and systems obligation.
The Act requires that insurers must pay sums due within a “reasonable time.” If cycle times drift or updates are inconsistent then costs climb with more repeat contacts, escalations and complaints.
Fairness risk is now shaped by how customer journeys perform, not only by what policy wording says.
Two paths to compliance: add layers, or remove friction
One approach adds layers—more scripts, disclaimers, QA checks, documentation, and manual controls on already fragmented processes.
This will ease short-term compliance pressure, but it quickly leads to more handoffs, slower resolution, increased workarounds, and reduced clarity.
This is often where organisations reach for technology as a shortcut. But automating poor processes only increases the scale of the problem - driving more rework, escalations, complaints, and cost.
In our view, approaching CoIA implementation as a narrow legal or technical exercise increases the risk of poor implementation outcomes and inconsistent treatment of policyholders.
– FMA, 18 May 2026
A simpler, smarter way: reduce friction and increase clarity
Organisations who treat regulatory change as an opportunity to simplify and improve their operating model gain a clear competitive advantage. They re-design how work gets done, remove inefficiencies, and build stronger, more adaptable foundations for future change.
In practice, this means:
• Treat this as a work re-design opportunity, not a compliance exercise
• Manage change and training holistically to avoid overload, duplication, and fragmentation
• Work back from November 2027-align process, technology, data and people early
• Bring in focused, independent expertise to accelerate progress and challenge thinking
• Identify and deliver high-impact simplification and efficiency gains across end-to-end journeys
• Use this clarity to enable re-platforming and confidently leverage AI
This approach reduces cost and risk while building a simpler, smarter business ready for what comes next.
Conclusion
November 2027 is closer than it seems. Act now to avoid last minute cost and risk, and turn CoIA into a competitive advantage.
Talk to us about a simpler, smarter approach. We’ll help you prepare your people, streamline your operating model, and identify what’s ready to automate today.
