In the UK TPAs might be forgiven for believing that the FCA 2026and coming 2027 insurance priorities are aimed at Carriers and MGAs rather than TPAs. But the challenges to capacity providers mean that they will ask you questions like these.

• "When we need you to reconstruct who held and gave authority to approve this payment on a specific past date, and prove the record hasn't been altered, how long would that take"?
• “Instead of waiting for 30-60 days for MI today, when will you be able to present us with real-time Claims MI”?
• “If a flood surge ( or bush fire surge) hits in 2027, how will your evidence chain hold up at 5x- 10x normal FNOL volume”?
• “The FCA is demanding that when, renewing terms we must ask for audited claims-handling MI and evidenced customer outcomes as conditions of capacity rather than being just good practice. How will you do that”? 

The liability flows from the Carrier through delegated authority to the MGA and thence to the TPA- or directly to the TPA. But the evidence chain must flow back.  

The FCA has confirmed it is expanding its review of oversight of outsourced claims processes to include different delegated authority models and remuneration arrangements. The failure mode is already documented — in the FCA's 2026 home and travel claims work, the most commonly cited failure was inadequate oversight of outsourced claims handlers.

• Insurers delegated and lost visibility
• Data did not flow back in a form permitting meaningful oversight
• Governance meetings produced no actionable MI
• Contractual audit rights went unexercised.

There are two ways for TPAs to look at this.

1. As a commercial benefit and competitive advantage to be more successful in contracting  and renewing outsourced claims
2. As a regulatory, governance and cost issue where liability lies with the capaciity provider to provide oversigh and auditability across the delegated authority chain

A commmercial benefit

TPAs able to answer those questions and provide the evidence with validated provenance coulld become indespensable to Carriers and MGAs, particularly those with multiple lines of business. The challenge for the TPA is that they generally already have a claims technology stack and deal with multiple principals so the last thing they need or want is to replace existing technology.

They need an evidential claims intelligence layer that integrates with their  current platform and lets them send claims MI in a format each MGA and carrier can ingest to meet their liabilities. MI that also proves how Delegated Authority was and is managed to the limits set. 

As a regulatory, governance and cost solution

TPAs are a critical part of the FCA  priorities if they like it or not. So best to harness the opportunity to change an apparent regulatory challenge into a competitive advantage. Consider this in terms of three interlinked parts.

1. Operational performance
   1. Automation that removes administrative trasks
   2. Claims handlers able to focus on judgements
   3. Cost per claim managed downwards whilst Duty of Care is maintained and improved
2. TPA appointment retention
   1. You present evidence that the DA terms are adhered to
   2. Executed consistently, responsibly, within agreed limits and SLAs across every book
   3. You become an indespensable TPA partner rather than a cost centre
3. Governance
   1. Documented decisions
   2. To Scheme specific authority
   3. Audit-ready record for every principal

Who best to deliver such solutions?

IMO it is a modern claims management platform vendor that does not require that you replace an existing platform but can add the DA Intellgence, Evidence and proven provenance Layer over your current platform. It must include a Governance Architecture leveraged from day one. If your own claims tech is ageing and unable to leverage AI Agents to reduce administration then you should also have confidence that you could upgrade and migrate at some future date.

I wrote of three modern claims platforms that should  be evaluated - Wilbur, Five Sigma and Snapsheet (See Sources Beyond FNOL)  To choose the best one I would recommend having strategic discussions with each and choosing the best fit to run an initial project with an MGA or Carrier to join in the project and prove that all three interlinked parts can be delivered for all the parties in the DA chain. Once proven you could get the MGA and/or carrier to help fund the deployment. You could also prove the business case for you the TPA licensing the DA, Evidence and Governance layer as a competitive differentiator.

Are there other alternatives?

• Aptly (authority cascade), Vitesse (payments under DA), Guidewire (native bordereaux and controls), Regure (Consumer Duty evidence), and Lloyd's DDM/DAM (reporting infrastructure for the subscription market).
• These do not however adress both parts of the two evidence models: a claim-level audit trail, and authority provenance (instrument, limits, named signatory, effective dates).
• Can they deliver the as-at reconstruction test? What authority existed on a given date, and can it be shown tamper-proof over the claims lifecycle?
• The unserved space with the gaps I describe above is the company market and non-Lloyd's MGA/TPA chains, plus authority provenance combined with claims operations.

I suggest it is good business sense to not wait, not rely on capacity providers but seek a strong competitive positioning that ensures our business and future. To  talk more please contact me

Sources

Beyond Digital FNOL- innovation across claims

Claim Multi-Agent and Automated Intelligence Platforms Promise Automation Benefits — But Read the Fine Print on Autonomy

El Nino, FNOL Surges and insurers' capacity to cope

The FCA’s changing approach to MGAs