The Lloyd’s 2026-2030 Strategy presents a more targeted direction for managing agents, outlining a more proportionate focus on the risks that affect financial performance, capital, regulatory permissions, operational resilience and market reputation. While looking to reduce some generic reporting activity over time, it also raises the standard of evidence around the controls and governance that remain.
Compliance teams now need to look carefully at where their time is spent. Administrative routines, duplicated tracking and broad checklist activity may feel safe in practice, but they will not be enough if the organisation cannot evidence how it is meeting the underlying principles.
The new oversight environment also places more weight on outcomes. Managing agents require evidence that governance is effective, data is reliable, operational resilience is understood, and delegated authority arrangements are properly controlled. The compliance function also still needs policies, registers and reporting, but organisations should understand whether those activities support better evidence, accountability and decision making.
Compliance leaders need to also ensure their own operating model can support the direction of the new strategy, which points to process simplification, common data standards, technology modernisation and targeted oversight. As Lloyd’s moves towards a more streamlined market model, the priority for compliance leaders is pointing towards evidence that shows processes are operating effectively.
Outcome-led governance raises the bar for evidence
Outcome-led governance changes the role of compliance. Rather than simply showing that a policy, control or committee exists, managing agents need to clearly show what those structures achieve, how issues are escalated, and whether the business is operating with the standards expected by Lloyd’s.
Under Principles-Based Oversight, a targeted and proportionate approach depends on confidence in the firm’s own governance and control environment. If the organisation can provide clear evidence, reliable data and a transparent reporting process, oversight can be better focused on the areas of real risk.
However, this evidence often sits across several places, posing a challenge for compliance teams. If areas such as reserving, capital, operational resilience and underwriting governance are not connected, compliance can spend too much time collecting evidence rather than understanding what it shows.
For example, a completed checklist may show that a review happened, but not whether the right risks were challenged. A governance pack may record a decision, but may not evidence how the decision was supported with data. As such, compliance leaders need to test their evidence against decisions, ensuring the information shows how the firm manages potential risks.
A stronger compliance function will still manage policies, reporting and attestations, but these activities now need to be connected to the risks prioritised as part of the new strategy set out by Lloyd’s.
Principles-Based Oversight reduces activity rather than accountability
Principles-Based Oversight is primarily designed to focus attention on areas that may pose the greatest risk. In practice, managing agents should exercise further scrutiny around the principles that affect financial strength, market integrity and operational control.
Compliance teams need to understand which activities genuinely support the principles Lloyd’s is prioritising, by identifying which activities help the firm to evidence how reserving, capital, underwriting, operational resilience, delegated authority and conduct risks are being managed in practice.
In turn, this changes how compliance teams should approach assurance. Reviews need to show whether controls are operating effectively, whether issues are escalated at the right level, and whether management information is strong enough to support decision making.
However, firms should also be aware of the risk in removing administrative effort without strengthening the evidence that replaces it. A more streamlined oversight model still requires disciplined compliance work behind it, with policies, controls and reporting that clearly connect to the organisation’s expected outcomes.
PRA and FCA alignment keeps baseline standards high
Aside from Lloyd's strategy, managing agents are also operating within wider PRA and FCA expectations around financial stability, market integrity, operational resilience, consumer outcomes and effective governance.
A more targeted Lloyd’s model may reduce unnecessary activity, but the baseline for operating in the market still places certain demands on compliance teams; they are still expected to understand how Lloyd’s expectations align with PRA and FCA priorities, particularly where regulatory change, operational resilience, data integrity or control effectiveness are involved.
During market modernisation, firms may be working through platform changes, process simplification, data standardisation and legacy system dependencies at the same time. These changes can create new control points and evidence requirements, even where the overall direction is towards a more efficient marketplace.
As such, compliance teams need to ensure that regulatory evidence is still connected across separate regimes. If Lloyd’s, the PRA and the FCA are each concerned with resilience, governance, financial stability or conduct outcomes, firms should be able to show a consistent view of how those risks are being managed.
The strongest position is to build evidence once and use it properly. Good data, clear ownership, documented decisions, control testing and reliable MI should support Lloyd’s oversight, PRA expectations and FCA scrutiny without creating parallel compliance processes for each audience.
The role for regulatory change leaders is important here, as they need to understand where market strategy, supervisory expectations and internal transformation overlap, then make sure the operating model can produce evidence that stands up across all three.
Data integrity is becoming a compliance issue
Compliance is now much more involved with data integrity than it has been in the past. Common data standards, digital processing and more targeted oversight all rely on information that is accurate, complete and available at the right point in the process. If data is corrected late, held in separate trackers or reconciled manually after submission, compliance teams may struggle to evidence that the business is operating within the standards expected.
For example, at the underwriting slip level, poor data quality at the point of submission can affect reporting, reserving, capital, delegated authority oversight and operational resilience. It can also create avoidable challenge if the firm cannot explain how information has been validated or where a figure has come from.
Compliance teams therefore need to understand where data quality issues are being managed through manual effort. In many organisations, experienced colleagues know which fields need checking, where reports need correcting, and which workarounds are required before information can be used. While this knowledge can keep the process moving, it also creates risk if the control depends too heavily on individuals rather than a standardised process.
ACORD-aligned records and common data standards should make evidence more consistent, but firms still need clear ownership of data validation and should know how the standard is applied, who checks the data, how exceptions are managed and how issues are escalated.
Stronger data integrity supports teams with better evidence, but also gives senior leaders, Lloyd’s and other regulators more confidence that the firm understands its own risk, capital and operational position.
Operational resilience and delegated authority need closer evidence
Market modernisation can create additional control pressure where firms operate with both old and new processes running concurrently, as data may move between systems, reporting may require manual checks, and third-party providers may support key parts of the operating model. Compliance teams therefore need to understand where these dependencies sit and whether the firm can evidence how resilience is managed during transition.
Similarly, delegated authority can also pose a challenge, as coverholders, MGAs and binder agreements can extend the firm’s risk and compliance across a wider distribution chain. If data is incomplete, reporting is delayed or local controls do not match the firm’s own standards, compliance teams may find it harder to evidence effective oversight.
Firms should now focus on how controls operate in practice. Compliance teams need to know whether delegated authority data is reliable, if expectations are visible early enough and whether issues are escalated through the correct governance route.
A more targeted oversight model may place more pressure here, as operational resilience, delegated authority and data integrity cannot sit as separate compliance workstreams if the risks overlap in practice.
Practical compliance actions
Compliance leaders should review where effort is being spent and whether current activity produces evidence that supports Lloyd’s more targeted oversight model.
Practical actions should include:
- Map compliance activity to Principles-Based Oversight. Review existing dashboards, trackers and reporting routines. Identify which activities provide meaningful evidence against Lloyd’s principles and which mainly prove that a task has been completed.
- Focus evidence on priority areas. Reserving, capital, operational resilience, delegated authority, underwriting governance and data integrity should have clear evidence routes, accountable owners and regular review.
- Review data validation at submission level. Firms should understand whether data is complete and accurate at the point it enters the process, rather than relying on later correction, reconciliation or manual checking.
- Connect Lloyd’s, PRA and FCA evidence. Where expectations overlap around governance, resilience, conduct, financial stability or control effectiveness, firms should avoid building separate evidence processes for each regime.
- Audit delegated authority and MGA oversight. Compliance teams should test whether binder arrangements, coverholder reporting and delegated authority controls match the firm’s internal standards and regulatory expectations.
- Test operational resilience evidence. Firms should be able to show how key services, systems, suppliers and processes are managed during transition, particularly where market modernisation creates old and new processes running in parallel.
- Reduce administrative compliance work where it does not support decision-making. Removing low-value activity only works if the firm strengthens the evidence, controls and governance that remain.
How Brighter Consultancy can support
We support London Market firms with regulatory change, compliance transformation and governance improvement, working with clients to review existing compliance processes, strengthen evidence frameworks, improve data and reporting, and support delivery across complex regulatory and operational change programmes.
As Lloyd’s moves towards a more targeted oversight model, we can help firms understand where current activity is creating value, where evidence may be weak and how compliance transformation can support stronger governance across the organisation.
If your organisation is reviewing its compliance operating model, delegated authority oversight or regulatory change priorities under the Lloyd’s 2026–2030 Strategy, speak to us.
