
Operations
Commercial insurance service standards from customer harm and capacity, with exceptions operated openly
Set commercial insurance service standards from customer harm and capacity, keep them separate from regulatory deadlines, measure quality, record exceptions openly.
Service standards should describe an outcome, clock, owner, evidence and exception route. A target such as "respond quickly" cannot be audited. Set internal measures from customer harm and operational capacity, then keep them distinct from legal or regulatory deadlines.
What to take away
- Set service standards from customer harm and operational capacity, not invented benchmarks.
- Keep internal targets distinct from legal or regulatory deadlines that may be binding.
- Measure quality alongside time, including accuracy, completeness, and recovery.
- Operate exceptions openly with recorded reasons, customer impact, and revised owners.
- Review standards monthly and after incidents, publishing performance with scope and exclusions.
Define the service points
Create standards for:
Service points to define
- Acknowledge new request
- Identify missing or inconsistent facts
- Obtain and compare quotations
- Issue approved policy documents
- Respond to mid-term change
- Receive and route incident or claim
- Update customer on progress
- Recognise and handle complaint
- acknowledging a new request;
- identifying missing or inconsistent facts;
- obtaining and comparing quotations;
- issuing approved policy documents;
- responding to mid-term change;
- receiving and routing an incident or claim;
- updating a customer on progress;
- recognising and handling a complaint;
- correcting inaccurate information;
- providing records during outage or exit.
For each, state when the clock starts, business-hour treatment, pause conditions, final outcome and evidence. Acknowledgement is not resolution.
A worked example: acknowledge a claim within 4 business hours of receipt during working hours. The clock starts when the claim enters the queue. It pauses only while waiting on customer information and resumes when that information arrives. Record the pause reason, owner and evidence.
Set targets from consequence
Prioritise loss-prevention, legal, expiry and claim-notification events above routine administration. An inaccessible claim route or expired compulsory cover can cause greater harm than a delayed marketing report.
Prioritise by consequence
Higher priority
- Loss prevention
- Above routine
- Legal events
- Above routine
- Expiry events
- Above routine
- Claim notification
- Above routine
- Marketing report
- Below
Routine administration
- Loss prevention
- Below
- Legal events
- Below
- Expiry events
- Below
- Claim notification
- Below
- Marketing report
- Above
The FCA's operational resilience insights for insurance firms highlight customer harm across purchase, amendment, renewal, claim and complaint journeys. Firms within scope must apply their actual regulatory framework; other businesses can still use the journey view to identify important dependencies.
For a severe event, use a named trigger and target. Illustrative: a system outage or claim surge above 2 business hours or 150% of the daily forecast is the trigger. The target is an interim customer update within 1 business hour and restored critical claim handling within 4 business hours.
Separate internal targets from rules
FCA Handbook ICOBS 8 requires insurers within scope to handle claims promptly and fairly, provide reasonable claim guidance and progress information, and settle promptly once terms are agreed. It does not create one universal number for every commercial claim.
Internal targets versus legal rules
Internal target
- Source
- Business decision
- Flexibility
- May be shorter
- Claim timing
- Pilot baseline
- Complaint timing
- Pilot baseline
Binding rule
- Source
- FCA Handbook
- Flexibility
- Cannot extend
- Claim timing
- ICOBS 8 prompt
- Complaint timing
- DISP 1 live rule
FCA Handbook DISP 1 contains complaint acknowledgement and response requirements whose timing depends on complaint type and current application. Calculate the legal date from the live rule. An internal target may be shorter but cannot extend a binding deadline.
A small commercial broker or MGA without full FCA claims scope should adapt ICOBS 8 and DISP 1 references to its own permissions and any delegated authority. Record which claim and complaint steps it owns itself and which sit with the insurer, principal or another authorised firm.
Measure quality alongside time
Track first-pass accuracy, reopened work, customer correction, missing document, wrong recipient, unresolved assumption and repeat contact. A fast quotation based on an incorrect activity is not good service.
Use a balanced record:
| Standard | Measure |
|---|---|
| Timeliness | Median and tail time, breaches and clock definition |
| Accuracy | Files passing independent review first time |
| Completeness | Required documents and fields available |
| Accessibility | Critical tasks completed using supported routes |
| Ownership | Work with a named next action and deadline |
| Recovery | Service restored and backlog controlled after outage |
Operate exceptions openly
Give staff authority to escalate unusual risks, vulnerable circumstances, legal uncertainty, unavailable systems and deadlines. Record reason, customer impact, interim action and revised owner. Do not manipulate metrics by closing and reopening cases.
Review standards monthly and after material incidents. Publish performance only with scope, period, sample and exclusions. The strongest standard tells the customer and team what will happen next while preserving a safe route when the ordinary process fails.
Design the reporting view
Show volume received, completed and still open beside the time measure. Separate work waiting on the customer, insurer, supplier and internal owner, but keep the original elapsed time visible. Record why a clock was paused and who authorised the pause.
Use percentiles or age bands as well as an average, since a small group of old cases can disappear inside a favourable mean. Report reopened and transferred cases so quick closure does not reward avoidable handoffs. Segment only where the denominator supports a responsible conclusion.
For a breach, state the affected outcome, interim protection, contact made, revised deadline and corrective owner. Review whether staffing, training, system design or a supplier dependency caused the problem. If the same breach recurs, change the operating control or target capacity rather than normalising the exception.
Give customers a straightforward way to report that a standard was missed. That feedback should join the case record and complaint route where it expresses dissatisfaction.
Before you act
- Define each service point with clock, owner, evidence, and exception route.
- Prioritise loss-prevention, legal, expiry, and claim-notification events above routine work.
- Pilot the workflow and measure baseline performance before approving targets.
- Calculate legal dates from live rules, not internal targets.
- Track first-pass accuracy, reopened work, and repeat contact.
- Record exception reasons, customer impact, and interim actions.
Common questions
How should targets be set for service standards?
Set them from the harm a delay would cause and the capacity you can resource. Start with claim notification, legal deadlines, expiry and loss prevention. Give each target an owner, a clock and an exception route, then test it before publishing it.
What is the difference between internal targets and regulatory deadlines?
Internal targets are yours; regulatory deadlines are binding and come from live rules such as ICOBS 8 or DISP 1. Your target can be shorter, but it cannot extend a legal date. Check your permissions and who owns each step.
How should exceptions be handled?
Let staff escalate vulnerable customers, legal uncertainty, system loss and missed deadlines. Log the reason, effect on the customer, temporary fix and new owner. If the same exception repeats, change the process or resource rather than normalising it.


