Client Profile.
The client is an EU-based digital insurer with a UK branch focused on consumer insurance products. Operating under the Temporary Permissions Regime (TPR) post-Brexit, the client sought full UK authorization from the PRA and FCA. Its business model relied heavily on outsourcing to its distribution partners and its parent company in the EU, necessitating a robust UK governance and operational framework.
Challenge.
To meet UK regulatory expectations, the client needed to transition from a branch model to a fully authorized UK entity. This required:
- A comprehensive governance structure
- Functional build-out across all core insurance operations
- Operational resilience planning
- Documentation and oversight of material outsourcing arrangements
The timeline was tight, and the UK entity had to be fully operational by the time the PRA was ready to authorize.
Solution.
We were engaged to lead the functional build, outsourcing work and operational resilience program. The engagement included:
Governance & Operating Model Development.
- Designing a full governance framework to include board and committee structures, SMCR documentation and executive management roles.
- Development of the operational documentation: meeting plans, templates, reporting structures and resource plans.
- Providing interim resources including a company secretary and CEO.
- Supporting the new full-time CEO, including with preparation for interviews with the regulator as part of their personal authorization.
Functional Build Across Core Areas.
We led the development of policies, procedures and oversight mechanisms across all functions, comprising:
- Internal audit: Charter, audit universe, annual plan and reporting templates.
- Risk: Strategy, ORSA process, risk register and controls documentation.
- Compliance: Manuals, risk registers, Consumer Duty and product governance reviews.
- Actuarial: Reserving, capital management, exposure policies and reporting.
- Finance: Ledgers, treasury, investment, reconciliation and reporting frameworks.
- Underwriting & Claims: Partner oversight, pricing, wordings, claims authorities and MI.
- Reinsurance: Strategy, recoveries, credit control and reporting.
- HR: Policies (e.g., whistleblowing, remuneration), SMCR lifecycle documentation and cultural alignment.
- Operations & IT: Procurement, facilities, IT policies and outsourcing oversight.
Operational Resilience Framework.
- Mapping the important business services (IBS) and supporting resources.
- Defining impact tolerances and conducted scenario testing.
- Developing an outsourcing policy aligned with PRA requirements set out in SS2/21.
- Creating a service management framework to oversee intra-group outsourcing with SLAs, KPIs and MI reporting.
Resources Deployed.
We assembled a multi-disciplinary team including:
- Directors and subject matter experts in governance, risk, compliance, actuarial, finance, HR, IT and operations.
- Interim executives and project managers.
- Talent pool consultants with deep insurance market experience.
Outcome.
The client has secured full UK authorization with a fully documented and operationally resilient framework. The build has enabled:
- The client to give confidence to the relevant regulators regarding their readiness.
- The delivery of a clear oversight of outsourced services.
- A scalable governance and operating model aligned with UK expectations.
Our structured approach and experienced team ensured that the client could meet its regulatory obligations while maintaining its digital-first, partner-driven business model.
