Playing to the Whistle: What Consumer Duty Demands from Your Documents

The 2026 FIFA World Cup is already throwing up moments that will be talked about for years. Germany’s 7-1 demolition of Curaçao. England’s breathless 4-2 win over Croatia, all seems an age away now. VAR overturning a yellow card given to the wrong player entirely. Underneath the drama on the pitch, something quieter is reshaping the tournament: the rules have changed, and not necessarily for the better.

New for 2026, VAR can now intervene on second yellow cards. Corner kick legitimacy is under review. Players have ten seconds to leave the field once substituted or their replacement waits. The referee’s word is no longer final, and teams that built their entire game plan around the old rulebook are being caught out.

Sound familiar?

In the UK insurance market, the rulebook changed too. The FCA’s Consumer Duty, now firmly embedded in day-to-day operations, has redrawn what good looks like. It is no longer enough to avoid doing harm. Insurers must actively demonstrate they are producing good outcomes and the document sitting in a customer’s inbox, the renewal notice, the policy summary, the claims decision letter, is one of the most visible places where that demonstration either holds up or falls apart.

The question every insurer should be asking right now is the same one every World Cup manager is asking their squad: are we playing to the new rules, or the old ones?

The New Rules of the Game

Before Consumer Duty, the compliance conversation around customer communications was largely about what not to do and these typically included, don’t mislead or use prohibited language and don’t omit material terms. It was a defensive game keep the ball out of your own net and you were broadly fine.

Consumer Duty changed the formation entirely.

The FCA now expects insurers to demonstrate four outcomes across every customer interaction: products and services that meet customer needs, fair value, consumer understanding, and consumer support. Of these, consumer understanding is the one that lives most directly in your documents.

Consumer understanding means that customers must actually be able to understand the communications they receive and not just that the communication was technically accurate. A renewal notice written in dense insurance jargon may be legally compliant and completely useless to the customer receiving it. Under the old rules, that was acceptable but under consumer duty, it is a risk.

The FCA has been explicit: boards must be able to evidence that their communications work for customers, not just that they exist. That shifts the burden from production to proof.

The Team Talk Problem

Here is where most insurers run into trouble, and it mirrors a challenge that plays out in every World Cup squad.

A national football team arrives at a tournament with a clear game plan. The manager has drilled the tactics. Every player knows the shape but the moment the squad is spread across the pitch facing different positions, different pressures, different moments in the game, individual interpretation creeps in. One midfielder presses high while another sits deep. The goalkeeper who was supposed to play out from the back, hoofs it long under pressure. I can’t stop thinking about Pickford in that first half against Croatia. The plan was consistent but sadly the execution was lacking.

This is precisely what happens in most insurance communications teams.

The compliance function has approved the language, while legal has signed off the templates. Marketing has provided clear brand guidelines. Then across hundreds of adjusters, brokers, relationship managers and customer service agents, each generating their own versions of letters, each making small edits, each adapting wording for the situation in front of them, the consistency dissolves. By the time a customer receives their renewal notice or claims decision, it may have passed through three drafts and bore no resemblance to the approved original.

Under Consumer Duty, every one of those variations is a potential failure of consumer understanding and unlike a poor tactical decision on the pitch, this one leaves a paper trail.

What the Referee Is Actually Looking For

The FCA has made clear what evidencing good consumer understanding looks like in practice. Firms are expected to:

• Test communications with real customers and demonstrate they work
• Use clear, plain English that is appropriate for the audience receiving it
• Explain decisions, not just state them — especially in claims and renewal contexts
• Tailor communications where the customer’s circumstances require it
• Maintain records that show consistent, controlled production of customer-facing documents.

This is not a checklist that can be satisfied by having compliance-approved templates sitting in a shared drive that nobody uses consistently. This requires the template to be the only version, the controlled, dynamic, living document that every communication flows from.

That is a technology problem as much as a policy problem and it is the problem that document automation solves.

Documill: The Tactical System Behind the Communication

Think of Documill as the tactical system that ensures every player on the pitch executes the same game plan, regardless of position, pressure, or personal preference.

Built directly inside Salesforce, Documill gives insurance teams a single controlled environment for generating every customer-facing document. Here is what that means for Consumer Duty compliance in practice:

• Plain English, locked in. Compliance-approved, Consumer-Duty-aligned language is embedded into templates. Adjusters and relationship managers do not draft from scratch, they generate from a source that has already been tested, reviewed, and approved. The plain English is not aspirational, it’s structural.
• Dynamic content that adapts intelligently. Consumer understanding is not one-size-fits-all. A straightforward home insurance renewal needs different language from a complex commercial liability decision. Documill’s conditional logic means the right content, the right explanation, the right level of detail, the right supporting information, is automatically included based on the data in Salesforce. The template adapts. The quality does not vary.
• No off-piste drafting. When a letter is generated through Documill, there is no blank page. There is no temptation to reword, abbreviate, or add a personal flourish that undermines the approved language. The document is generated, not drafted. The manager’s game plan is the one that gets played.
• Audit trails that evidence the outcome. When the FCA asks how you evidence consumer understanding, Documill gives you the answer. Every document generated is logged, who created it, from which template version, when it was sent, and whether it was received. That is an evidencing trail built into the process, not assembled after the fact.
• Consistent delivery across every channel. Documill sends documents via email, portal, mobile, or print, all from within Salesforce, all tracked. Whether a customer is digital-first or prefers paper, the communication they receive is consistent, controlled, and measurable.

The Substitution Bench: When Things Go Wrong

Even the best-prepared teams face moments when the plan breaks down. A player gets injured, the opposition changes shape after a water break or a VAR decision goes against you. In the World Cup, the substitution bench is where managers respond, tactical changes, fresh legs, a shift in approach.

Consumer Duty has its own substitution moments: complaints.

Under the Duty, how an insurer handles a complaint is itself evidence of consumer understanding and support. A complaint poorly handled, slow response, opaque language, a letter that fails to explain the outcome clearly – these are not just service failures, they are Consumer Duty failures.

Documill’s complaint response workflows ensure that when things do go wrong, the response is as controlled as the original communication. Complaint acknowledgement letters are generated on day one, automatically. Decision letters are templated to explain outcomes in clear terms, even your emails are.

The substitution works and the game plan holds.

The Offside Trap: What to Avoid

There are two traps insurers commonly fall into when approaching Consumer Duty communications, and both are as costly as an offside trap sprung at the wrong moment.

The first is confusing compliance with communication. A document that meets every regulatory requirement can still fail the consumer understanding test. Length, jargon, structure, and reading level all matter. A six-page renewal notice that buries the key information in the paragraph four is technically compliant and practically useless. Documill’s template design approach, informed by plain language principles and built for the audience, addresses this by design rather than as an afterthought.

The second is treating Consumer Duty as a one-time project. Some insurers reviewed their templates in 2023 when the Duty came into force and have not revisited them since, but the Duty is an ongoing obligation. Boards must be able to evidence consumer understanding on a continuous basis, which means templates need to be reviewed, updated, and evidenced regularly. Documill’s version control, clause library and template management makes this an operational reality rather than a compliance aspiration.

Full-Time Score: Consistency Wins

The teams that perform best at this World Cup will not necessarily be the most individually talented. They will be the ones who execute consistently while delivering the same quality of performance in the group stage as in the knockout rounds, under pressure, against difficult opponents, when the margin for error is the smallest.

Consumer Duty asks the same of insurers and doesn’t reward exceptional communications sent occasionally. Consumer duty rewards consistent, clear, evidenced communications sent every time, to every customer, from every team member, across every touchpoint.

Document automation is how consistency becomes structural rather than aspirational. With Documill, insurers stop relying on the individual performance of adjusters and agents, and start delivering the kind of repeatable, controlled communication quality that Consumer Duty demands.

The referee is watching along with the VAR screen is on and the rulebook has changed.

It’s time to play to the new rules, but don’t get me started on the 4^th place in the table rule, which makes the third game almost irrelevant!

Want to see how Documill helps insurers evidence Consumer Duty compliance through controlled, consistent document automation?

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Documill is the all-in-one document workflow automation solution for Salesforce integrating document generation, approvals, collaboration, and e-signatures into a single platform used by insurance teams across Europe.