Successful regulatory reform adoption is proven when customer journeys remain consistent under pressure. Decisions stay aligned across channels, customers receive timely and clear updates, and evidence is captured as part of the flow, so outcomes are explainable and defensible. Complaints do not spike simply because of a volume surge, and frontline teams are not forced into heroics to compensate for gaps. A failed adoption is exposed when the operating model cannot produce “reasonable” outcomes consistently when pressure hits.
That is the lens Sysdoc brings to the Contracts of Insurance Act 2024. Not as lawyers, brokers, or product owners, but as operating model and transformation practitioners. We work with insurers to identify where journeys break, then redesign processes, decision pathways, and evidence capture so outcomes are consistent, defensible, and cost-effective at scale. If you lead risk, compliance, claims, underwriting, operations, or finance, this will not just land as a compliance programme. It will surface in your cost-to-serve, your dispute outcomes, and the pressure on your frontline teams.
Most summaries say the Act modernises disclosure and remedies across consumer and commercial insurance.
The Act shifts the focus from what a customer should have disclosed to what insurers and intermediaries can evidence they asked, captured, followed up, and decided.
We see this concentrating pressure in three places that executives need to pay attention to because they drive brand trust, disputes, and cost-to-serve.
Consumers must take “reasonable care” not to make a misrepresentation before a consumer insurance contract is entered into or varied. But the Act does not treat this as a one-sided burden. It makes insurer behaviour relevant to the assessment, including how clear and specific questions were, what happened when answers were incomplete or irrelevant, and how the importance and consequences of answers were communicated. Fairness risk is now shaped by how your customer journeys perform across channels, not only by what your policy wording says.[1]
For non-consumer insurance, the duty becomes “fair presentation of the risk” and must be made in a manner that is “reasonably clear and accessible” to a prudent insurer. This elevates the value of disciplined data capture and traceability: what was known, what was asked, what was followed up, and why terms were set. If that record is patchy, defensibility will weaken. [1]
The Act implies a term into every contract that when a claim is made, the insurer must pay sums due within a “reasonable time” once that amount is determined. The keypoint is not speed for its own sake. Timeliness becomes part of “reasonable” behaviour in the contract itself. If cycle times drift or updates are inconsistent, costs climb fast and the risk of leakage increases. You see more repeat contacts, more escalations and complaints, more reopenings, and greater pressure on frontline teams. [1]
The Act uses “reasonable” because law needs a standard to apply, but from a customer perspective, “reasonable” means fairness. Did you ask me clearly? Did you tell me what you needed? Did you treat me consistently? Did you explain the decision in plain terms? Did you move at a pace that did not make me feel rushed? “Reasonable” is the legal word and fairness is the lived outcome. [1]
Delay and confusion are not theoretical risks, they already show up in dispute volumes. The Insurance and Financial Services Ombudsman Scheme reported record enquiry volumes and noted customer service issues and delays as key reasons people contacted the scheme, alongside a record number of investigated complaints in 2023/24. FSCL likewise reports rising complaints and disputes in recent years, reinforcing that dispute handling is not an edge-case process. It is an operating reality with direct cost and reputational impact. [3][4]
The FMA says “insurers should be progressing their planning and implementation activities to support readiness and a smoothtransition when CoIA comes into effect.”
All insurers will comply. The real decision is how they implement the change.
One approach is to add layers to meet the minimum. In practice, that looks like newscripts, disclaimers, QA checks, training modules, and manual controls bolted onto already fragmented journeys. It can calm immediate compliance anxiety, but it usually comes with a price in the form of more handoffs, slower resolution, and more scenarios where context gets lost and accountability becomes vague.
This is where it can get worse. Organisations lean on technology to smooth things over. A warning from experience: if you put automation on top of chaos, you scale the chaos. The outcome is inevitably more rework, more escalations, more complaints, and a hit to the bottom line. This is not just our view. Measurement maturity in automation programmes is often weak, which increases the risk of inconsistent outcomes at scale. Gartner has noted that fewer than 20% of organisations have mastered measurement of hyper automation initiatives.[5]
The alternative is to redesign to win, and this is where the stakes are bigger than the Act. Regulatory change is not a one-off event; it’s business asusual. The common pattern we see is organisations choosing to do “just enough” and accumulating workarounds, manual controls, and exceptions that slow journeys and slowly wear out both processes and people. It feels manageable until the next change lands, volumes spike, a weather event hits, or a supplier chain is compromised. That is when pain points become incidents.
Redesign to win treats this compliance obligation as an opportunity to remove friction. It means simplifying journeys, reducing handoffs, defining standard decision pathways and explicit exception handling, and building evidence capture into the flow so fairness does not depend on frontline heroics. The payoff is not only compliance. It is resilience, so when pressure hits, outcomes stay consistent because the system is designed to carry the load. [1]
In our experience, processes break where pain points live. Handoffs, delays, missing context, inconsistent rules, and opaque communication are the usual suspects. If we look at the end-to-end journey from claim lodgement to triage, triage to assessment, assessment to suppliers, suppliers back to the insurer, decision to communication, communication to escalation, every handover point is an opportunity for information to lose context and accountability to blur. For example, when “time to first meaningful update” varies wildly by team or channel, customers interpret delay as lack of care. A week of silence feels like avoidance, even when the file is moving internally. That is when complaints accelerate, even before a coverage decision is made. [3]
It’s not an endless transformation programme but a disciplined sequence.
1. Redesign the operational processes (sales, service, and claims) and remove unfairness at the source
2. Train for consistency and make fairness a way of working
3. Ensure data mapping and system integration requirements are clear and implemented so the right information shows up at the right time
4. Automate what you designed, including AI where it helps
In practice, defensibility is auditability. Can you reconstruct what happened directly from records?
Here’s the test we use because it cuts through optimism fast: if a dispute body asked you to prove you acted reasonably and consistently, could you do it quickly from system records, without relying on “who was on shift” or a claims manager reconstructing the story after the fact?
If the honest answer is “it depends,” that’s the risk. “It depends” usually means outcomes vary by team, channel, workload, and how much context survived the handoffs. That is exactly how disputes become expensive, not necessarily because the original decision was wrong, but because the organisation cannot demonstrate the journey, the reasoning, and the follow-up with confidence.
There’s a second test too, and it’s operational: when the system is under pressure, do you get more clarity or more noise? If the same period of stress triggers spikes in repeat contacts, reopened cases, complaint escalations, and workforce burnout, your operating model is telling you it is already at the edge. The Act simply raises the consequences of staying there.
Insurers that use the runway to redesign journeys, embed evidence, and automate with discipline reduce dispute risk and cost-to-serve while strengthening brand trust. Those who wait risk a late scramble, layered controls and fairness that varies by team, channel, and workload. [1][3]
Most insurers are not short onintent but have limited time and capacity. BAU teams are already oversubscribed, and end-of-runway panic is where cost escalates and risk increases.
Partnering with Sysdoc brings three practical things to the table: capability, capacity, and speed. We bring experienced practitioners who can design and deliver the change cost-effectively, while leaving behind an operating model your team can run and maintain. We bring delivery horsepower to get the work done without overwhelming BAU teams who still have to run the day job. And we help you use the runway now to avoid rushed decisions, bolted-on controls, and the quality and risk impact that follows.
In practice, we typically support insurers through an operating model impact assessment,value-stream redesign across the three fairness-critical streams (consumer journey, commercial journey, underwriting and claims-to-payment), training uplift for consistency, and automation readiness so technology doesn’t become an expensive workaround.
15 November 2027 is right around the corner. If you want to avoid the end-of-runway rush and turn compliance into advantage, let’s talk now. We will walk you through what designing fairness looks like for your operating model and help you prioritise which business processes to redesign first, what to train, and what is genuinely ready to automate today.
To explore what we do in financial services and how we have helped insurers uplift operational capability, see our Financial Services overview and our casestudy on uplifting process capability.
References
[1] InsurTechNZ panel notes and commentary on the Contracts of Insurance Act 2024 and innovation opportunities (February2025):
[2] MBIE, “Contracts of Insurance Act 2024:commencement and regulations” (proactive release) discussing commencement approach and alignment to 15 Nov 2027 longstop.
[3] IFSO media release on record enquiries and complaints and noting delays and customer service issues as key drivers (2023/24).
[4] FSCL annual reporting showing rising complaints and disputes and fairness framing.
[5] Gartner press release (Sep 2024) noting fewer than 20% of organisations have mastered measurement of hyperautomation initiatives.
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