Project Overview
A UK FCA-authorised direct motor insurer with £280M GWP (Gross Written Premium), 420,000 policies, and FCA Con...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised direct motor insurer with £280M GWP (Gross Written Premium), 420,000 policies, and FCA Consumer Duty obligations needed to modernise their motor insurance platform — replacing legacy Ageas Guidewire on-premises and telephone-based claims FNOL with a digital-first platform. FCA ICOBS (Insurance Conduct of Business Sourcebook), FCA Consumer Duty PS22/9 (renewal pricing — FCA PS21/11), MID (Motor Insurance Database — mandatory DVLA notification), Motor Insurers' Bureau (MIB — uninsured drivers database), DVLA V5C API (vehicle verification), MIAFTR (Motor Insurers' Anti-Fraud and Theft Register), UK GDPR, and WCAG 2.1 AA were mandatory. Budget: £180,000.
Our Approach
UK motor insurance telematics
black box telematics (hardware device installed in vehicle) or smartphone telematics (iOS/Android app using phone GPS and accelerometer).
Telematics data
driving score (speed, acceleration, braking, cornering, time of day — composite score per journey), mileage (actual vs estimated at renewal), area (postcode of most frequent driving).
FCA Consumer Duty PS22/11 telematics
usage-based insurance must offer lower premiums for low-mileage and safe drivers — actuarial evidence required.
Telematics platform
AWS IoT Core (device data ingestion — MQTT, 10-second updates per journey) → Kinesis (stream processing) → S3 (journey archive) → SageMaker (driving score ML model) → policy database (score update per renewal).
FCA PS21/11 Renewal Pricing Compliance
FCA PS21/11 (General Insurance Pricing Practices): from January 2022, insurers cannot charge existing customers more at renewal than equivalent new customer price.
Renewal pricing compliance
- 1renewal price must not exceed new customer equivalent (same risk profile, same distribution channel),
- 2renewal quote generation: price calculated from current risk factors (age, vehicle, address, claims history) — same model as new customer quote,
- 3renewal walk-away right disclosed (customer can cancel without penalty at renewal),
- 4renewal comparison shown (last year's premium vs this year's — explicit percentage change), (5)
FCA reporting
annual renewal pricing data reported to FCA (GABRIEL supervisory return).
Automated PS21/11 check
- renewal price → new customer equivalent price API → if renewal >
- new customer → automatic reduction to parity.
MID and DVLA Integration
MID (Motor Insurance Database): every UK motor insurance policy must be notified to MID within 24 hours of inception.
MID API
- 1new policy notification (vehicle registration, policy number, inception date, expiry date, insured name),
- 2policy cancellation notification (MID removal on cancellation),
- 3policy renewal notification (continuous cover maintained).
DVLA V5C API
- vehicle details (make, model, engine size, registration date — from DVLA V5C database) used for risk rating.
- DVLA continuous insurance enforcement (CIE): DVLA cross-references MID against DVLA vehicle register — SORN or uninsured → DVLA enforcement action.
- MIAFTR (Motor Insurers' Anti-Fraud and Theft Register): vehicle write-off records — check at quote (previous write-off affects risk rating and insurability), total loss notification (after claims settlement).
Digital Claims FNOL and Repair Network
FNOL (First Notice of Loss) digital: customer reports claim via web/app (not phone — Consumer Duty consumer support outcome).
FNOL capture
accident date/time, description, third party details, injuries (if any), photos (upload from mobile).
Liability triage
- 1non-fault (liability clearly with third party → third party insurer notification via MIB Claims Portal),
- 2fault (customer at fault → own damage repair),
- 3disputed (liability unclear → claims handler review).
Approved repairer network
280 UK approved repairers (postcode search) — customer selects repair centre, appointment booked via API.
Courtesy car
automated courtesy car booking from approved repairer partner (repairer confirms availability → customer notified).
Claim settlement
- 1repair estimate approved (Audatex repair estimate tool — insurer/repairer shared),
- 2payment to repairer (GoCardless B2B BACS),
- 3customer notification (GOV.UK Notify).
The Results
FCA ICOBS and Consumer Duty compliance confirmed.
Platform live at 26 weeks, £168,000 — under budget. 420,000 policies migrated.
Digital FNOL adoption: 78% (target: > 70%).
MID notification accuracy: 100% within 24 hours.
FCA PS21/11 renewal pricing: 100% compliant (zero parity failures).
Telematics driving score: 28% of policyholders earning safe driver discount (average £84 saving).
Claims settlement time: 8.4 days average (legacy: 18.2 days).
Customer NPS: 72 (legacy: 24).
DVLA V5C accuracy: 99.8%.
MIAFTR check: 124 write-off flagged at quote (prevented fraudulent reinstatement claims).
“Digital FNOL 78%. MID 100% within 24 hours. PS21/11 zero parity failures. Telematics 28% earning discount. Claims settlement 8.4 versus 18.2 days. NPS from 24 to 72. MIAFTR 124 fraudulent reinstatements prevented. The telematics driving score — 28% of customers earning an average £84 discount — changed our product from commodity motor insurance to a product that rewards good driving. Consumer Duty reward for value: our lowest-risk customers now pay fair prices. ClickMasters built the actuarial model and the IoT pipeline simultaneously." — Chief Product Officer, UK Direct Motor Insurer (name withheld)”
Project Details
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