Ireland’s renewal runway is now eight weeks: a chase plan for brokers
Two notifications, at least 40 working days before the renewal date. How an Irish brokerage turns the Consumer Protection Code 2025 clock into a chase plan.
A day-by-day renewal sequence for UK commercial brokers on WhatsApp: when to invite, which documents to chase, premium finance and Consumer Duty checkpoints.
A commercial renewal rarely goes wrong on renewal day. It goes wrong six weeks earlier, when the updated turnover figure never arrived, the claims experience was requested twice by email and the client only read the renewal terms on the Friday before inception. WhatsApp does not fix a disorganised renewal, but it does shorten every round trip: a proposal form photographed and returned in ten minutes, a question about the excess answered while the client is on site. This playbook lays out a 60-day sequence that UK brokers can run on a firm-controlled WhatsApp Business number, with the regulatory checkpoints that apply along the way.
Two frameworks shape the sequence. The first is the FCA Handbook. ICOBS 6.5 sets renewal disclosure rules for consumers: last year's premium alongside this year's, a statement about automatic renewal, and, from the fourth renewal, the wording inviting the customer to shop around. Those rules are written for consumer policies of ten months or more, so a pure commercial account is not caught by them. The second framework is the Consumer Duty, which does reach most SME clients because the Duty applies wherever ICOBS applies, with carve-outs for reinsurance and for contracts of large risks placed with non-consumers. For a tradesman's liability package, a shop's combined policy or a small fleet, the prudent assumption is that the Duty's four outcomes apply, including fair value and consumer support.
What that means for a messaging channel is simple: the firm must be able to show what it sent, when, and that the client could reasonably understand it. A renewal invitation pushed from an account handler's personal phone fails the evidencing test even if the content is perfect. The 60-day plan below assumes one brokerage number, a shared inbox and templates approved by Meta for the messages the firm initiates.
| Day | Action | Channel and message type | Why here |
|---|---|---|---|
| D-60 | Open the renewal file; send the "renewal approaching" message asking for updated turnover, wage roll, vehicle list or sums insured | WhatsApp utility template (firm-initiated) | Markets need clean data four to six weeks before inception |
| D-50 | Chase missing documents with a checklist; accept photos and PDFs in the thread | WhatsApp, inside the 24-hour service window when the client replies | Most delays sit here, not at the insurer |
| D-35 | Confirm the demands and needs: anything changed (new premises, new activity, contractors, cyber exposure)? | WhatsApp question, followed by a written summary by email | Feeds the suitability record |
| D-21 | Send renewal terms: premium, cover summary, key exclusions, premium finance option with total cost | Email or client portal for the document; WhatsApp notification that it is there | Leaves time to compare without a last-minute decision |
| D-14 | Reminder; offer a call for anything the client wants explained | Consumer support outcome | |
| D-7 | Instruction deadline; explain what happens if no instruction is received (no cover, or auto-renewal if the policy provides for it) | WhatsApp plus email | Avoids an accidental lapse |
| D-0 | Confirm cover bound; send or point to the policy documents and the premium finance agreement | WhatsApp confirmation, documents on durable medium | Evidence of inception |
The calendar is indicative. A D-60 start suits annual commercial accounts with several sections; a small package policy can run on a 30-day version of the same sequence. What should not change is the order: data first, terms second, decision third.
Commercial renewals stall on a short, predictable list of documents. The WhatsApp request works best as a numbered checklist the client can tick off by sending photos:
The photos and PDFs the client sends back belong in the client file, not in a phone gallery. With ORIS the thread sits in the shared inbox next to the customer record, and the team can export a CSV of customers and opportunities for the firm's own systems; there is no native connection to broker management software, so the handler still saves the documents where the firm keeps its renewal file.
Many SMEs pay monthly. When a broker offers instalments through a third-party premium finance provider, ICOBS 6A.5 requires the firm to show the total cost with and without finance, the difference between the two, and a statement that finance costs more than paying upfront. The FCA's premium finance market study (MS24/2, final report published in February 2026) decided against a price cap but made clear that firms must be able to demonstrate fair value for their finance arrangements and that offering "monthly or annual" as the only choice does not evidence an active election by the customer.
On WhatsApp, that translates into a short, neutral message: "Your renewal premium is {montant} if paid in full. If you prefer to spread it over 10 monthly instalments, the total cost becomes [total], which is [difference] more. Both options are in the attached terms — tell me which you would like." The detailed finance agreement and the pre-contract credit information are delivered on a durable medium, not as a chat bubble. The chat is for the question, the decision and the confirmation.
Meta requires pre-approved templates for any message the firm sends outside the 24-hour window that follows a client's last message. Three utility templates cover most of the 60 days:
Each reply lands in the shared inbox, where the handler sees the renewal date, the open quote and the last contact. A "renewal_reminder" lifecycle trigger in ORIS can prepare the D-60 campaign as a draft a set number of days before the renewal date, and the team decides who to include. The sequence is the broker's; the tool removes the spreadsheet. More patterns are collected in the follow-ups and renewals section and in the use cases.
Under the Duty, the renewal itself is a product-and-price moment. Keep a note of the market exercise (which insurers were approached, why the holding market was retained or replaced), of the remuneration on the policy and on any premium finance, and of how the client was told about it. The WhatsApp thread provides timestamps for every step; the broker's written summary provides the reasoning. If a complaint later reaches the Financial Ombudsman Service, the combination of the two is what the firm will be asked to produce. Firms already running a shared inbox under Consumer Duty have most of this in place; the renewal playbook simply gives it a calendar.
ICOBS 6.5 is written for consumers renewing general insurance policies of ten months or more. A purely commercial account is outside it, but the Consumer Duty and the general ICOBS customer's best interests rule still apply to most SME clients, so the same discipline on timing and clarity is advisable.
A PDF can be sent in the thread, but the firm should treat email or a client portal as the durable medium for the terms, the policy summary and any credit agreement, and use WhatsApp to notify, remind and answer questions. That keeps the evidencing of disclosures clean.
Answer within the 24-hour service window that the client's message opens, confirm the instruction in writing the same day and record the time. If cover cannot be bound in time, say so plainly and explain the consequences of a gap rather than implying cover continues.
Five to seven firm-initiated messages over 60 days is typical for an account with several sections. If the client has not answered two consecutive reminders, switch to a phone call rather than sending a third template.
A renewal message about an existing policy is a service communication, not marketing, but Meta still requires that the number has opted in to receive WhatsApp messages from the business. Record that opt-in in the client file and honour any STOP request immediately.
Shared WhatsApp inbox, client records, follow-ups and opportunities for the whole brokerage. 15-minute demo.
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