When WhatsApp goes down: continuity and incident reporting for brokers
A WhatsApp outage is a service failure for your brokerage. What FCA PS26/2, DORA and the Consumer Duty actually require, plus a continuity plan.
A clean mid-term adjustment process on WhatsApp: confirm instructions in writing, evidence endorsements and premium changes, and protect the firm from E&O.
Nothing tests a brokerage's process discipline like the mid-term adjustment. An MTA arrives as a fragment — “we've bought another van”, “my son passed his test, add him”, “we're moving the stock to the new unit next week” — usually on whatever channel the client finds quickest, increasingly WhatsApp. It is small, routine, interruptive work. It is also, per pound of premium, some of the most dangerous work a broker does: an uninsured vehicle on the road or stock sitting at an address the insurer has never heard of is precisely the kind of gap that surfaces at claim time and lands on the firm's errors and omissions cover. The channel is not the problem. An unfinished process is.
Three properties make mid-term changes riskier than new business or renewals. First, they arrive informally, mid-conversation, without the ceremony that triggers checklists. Second, they look complete before they are — the client believes cover changed when they sent the message; in reality nothing changed until the insurer endorsed the policy. Third, the evidence is scattered: a voice note here, a call there, a handset that left with a departing employee. When a claim hits the gap, the question is always the same — who knew what, when, and what did the firm do about it? — and the firm that cannot answer from its records is the firm that pays. The FCA Handbook's record-keeping expectations (ICOBS and SYSC) point the same direction for regulatory purposes: keep adequate records of the business you transact.
WhatsApp, handled properly, actually improves on the phone call it replaces: the client's instruction arrives already in writing, timestamped, in their own words. The task is to keep it that way — on a firm number, in a firm archive, connected to the confirmation that closes the loop. A chat that meets the standard of a durable medium is evidence; a chat on a personal handset is a liability.
Most MTA friction is money friction. Additional premiums, return premiums, insurer minimum-premium rules and any adjustment fees under your own terms of business hit clients as surprises when the first they hear is a debit. Handle it inside the thread:
| Situation | What to tell the client, before processing |
|---|---|
| Additional premium | The estimated amount (or “the insurer will quote — I'll confirm before binding”), the effective date it is charged from, how it will be collected |
| Return premium | The estimated refund and the insurer's basis for calculating it — clients assume pro-rata; some policies and minimum premiums say otherwise |
| Broker adjustment fee | Named and stated per your terms of business, not discovered on the invoice |
| No premium change | Say so explicitly — “no change to premium” is information the client wants in writing too |
A quoted figure in the chat, agreed by the client before you bind, converts the most common source of MTA complaints into a non-event. For fleets, where additions and deletions are constant, a standing pattern helps — the commercial motor fleet use case shows the rhythm, and a saved vehicle addition template means every handler asks for the same details in the same order.
The test for your MTA records is simple: could someone who was not involved — a new handler, an E&O insurer's solicitor, an FOS adjudicator — reconstruct the transaction from the file alone? That requires the instruction, your restatement, the client's confirmation, the insurer's endorsement, your closing confirmation with premium, all timestamped, all attributable to named people, all retained on firm systems. It also requires the uncomfortable discipline: when a client instructs something you advised against, or declines cover you recommended, that exchange goes in writing in the same thread. “Noted that you've decided not to increase the stock sum insured — my recommendation remains X” is one sentence of typing and an entire defence.
ORIS gives the MTA loop a home: a shared inbox on the brokerage's own WhatsApp number, where the instruction, the documents, the confirmation and the premium message live in one thread attached to the client record — visible to whoever handles the next message, searchable when the question comes back two years later, exportable to CSV for the E&O file. Handlers work from the same saved templates, so step two's magic sentence — “cover has not changed until I confirm” — goes out every time, not just when the most careful person is on shift.
The client's instruction can validly be given in a chat, but cover changes when the insurer endorses the policy, not when the message is sent. That is exactly why the process must say so explicitly and close the loop with a written confirmation once the endorsement is issued.
Follow your agreed arrangements with the insurer — some schemes and fleet policies give brokers limited authority or an emergency line. Never imply cover you cannot bind; confirm what you have actually secured and when, in writing, as soon as you have it.
Accept them as the client's preferred way of talking, but always type the instruction back and get a written confirmation. A voice note is hard to search, easy to mishear and awkward as evidence; your restatement fixes all three.
As long as the rest of the client file, under your firm's retention policy — bearing in mind that liability claims can surface years after the policy period. An MTA thread is part of the placing record, not casual chat.
Not necessarily — the calculation depends on the policy terms, and minimum-premium or short-period rules can reduce or eliminate a refund. Check the wording before quoting a figure, and attribute the basis to the insurer when you confirm it.
Shared WhatsApp inbox, client records, follow-ups and opportunities for the whole brokerage. 15-minute demo.
A WhatsApp outage is a service failure for your brokerage. What FCA PS26/2, DORA and the Consumer Duty actually require, plus a continuity plan.
PRIN 2A.8 asks your board to sign off client outcomes yearly. What the FCA found thin, what CP26/23 would change, and where the evidence already sits.
A text thread hides the signals a phone call reveals. How brokers identify vulnerability on WhatsApp, record it lawfully and prove outcomes under FG21/1.