The Coordination Gap

What happens when a claim crosses firm boundaries in the London Market, and what happens when the regulator asks for proof

In the London insurance market, no one writes risk alone. A single policy might sit across a lead syndicate and dozens of followers. It is an elegant structure that has worked for centuries.

But what happens at claim time?

The lead reviews the evidence and makes decisions. The following market accepts those decisions. The system moves. But there is no shared view of what the lead actually did, no structured protocol for keeping everyone aligned, and no infrastructure connecting the platforms different firms use.

This is not a criticism. It is a research finding. 

The system runs on trust, and that is both its strength and its vulnerability.

Over the past year, I have been speaking with senior claims professionals, compliance leads, operations directors, and technology leaders across the London Market. The conversations have been remarkably consistent.

One senior claims director described a billion-pound energy loss involving more than twenty markets and multiple overlapping policies. Everyone is appointing their own lawyers. No shared protocol. Her suggestion was practical: a claims protocol to keep everyone aligned.

A COO at a casualty syndicate offered a different view. For his business, this is not a problem. They lead their own claims and trust the lead on everything they follow. The coordination gap, he explained, lives in the subscription market, not everywhere.

A CTO with nearly three decades of building insurance platforms put it bluntly: no structured record of what the previous reviewer actually assessed—a data problem at the core.

And a conduct risk lead at a managing agency said her team focuses on outcomes, not process. She was not concerned about cross-firm evidence because her function measures results, not the steps that produced them.

Most practitioners are comfortable with how the system works today.

But the regulator is not.

The compliance-operations blind spot

If compliance teams measure outcomes and operations teams manage processes, who produces evidence of how outcomes were reached across firm boundaries?

The answer, across every conversation I have had, is: nobody. Not because anyone is negligent, but because the evidence was never designed to travel beyond a single organisation.

This did not matter when the regulator measured process compliance. It matters now because the regulator is asking for proof of outcomes, and that proof depends on evidence that crosses firm boundaries.

The regulatory landscape has shifted

Since January 2026, claims have been elevated to hurdle status at Lloyd's with named accountability at the board level. The FCA, following the consumer super-complaint, reviewed 23 insurers and found that 5 had limited control over outsourced claims. Six had no documented oversight frameworks. Since July 2025, the FCA has opened two enforcement investigations, commissioned three independent reviews of firms' claims systems, required three senior managers to attest to strengthening controls personally, and placed one firm under business restrictions. The delegated authority review is expanding this quarter.

The gap is not in how claims are handled. It is in how handling is evidenced when the regulator asks. Today, most practitioners do not feel this is a problem. Whether that remains the case as the FCA's delegated authority review progresses and enforcement actions become public is the question this research is tracking.

Looking ahead

The window between now and early 2027 may be the period in which the market finds out whether trust alone is enough or whether structured evidence of cross-firm coordination becomes a requirement.