Digital Platform Providers

About Digital Platform Providers

A Digital Platform Provider (DPP), previously known as a ‘Product Partner’ is a third-party entity that uses an automated online platform to automatically bind policies and issue policy related documentation on behalf of a managing agent or coverholder. The online platform may be owned by the DPP themselves or owned and provided by the managing agent or coverholder.

The online platform is intended to facilitate the sale of insurance products that are suitable for underwriting using fixed rating and underwriting criteria, with no discretion granted to the DPP, to i) accept or decline the risk ii) to amend any terms iii) amend any rates to be applied.

These types of arrangements are suitable for the selling of insurance products by both fully authorised insurance firms and also firms whose main business is not insurance, but who wish to offer simple, related insurance products alongside their main non-insurance products. The DPP must be appropriately licenced for the activities they wish to carry out in the relevant territories.

Why guidance is needed

The Intermediaries Byelaw allows Lloyd’s discretion to permit firms other than those listed in the Byelaw to have delegated authority (see in particular paragraphs 1(e) & 3(f) of the Intermediaries Byelaw).

Lloyd’s has provided that subject to meeting the criteria set out in this section, delegation of authority to bind policies and issue contractual policy documentation can be permitted to DPP’s (as defined below) without them being approved as coverholders.

Benefits of being a Digital Platform Provider

Access to specialist products

Lloyd’s offers a wide range of specialist insurance solutions across multiple classes of business. DPP can utilise their local network to provide products to meet the needs of niche markets as well as emerging risks.

Collaboration

DPP work closely with experienced Lloyd’s underwriters and brokers to develop innovative and bespoke insurance solutions for their local markets.

Global network

Lloyd’s extensive global network provides regulatory guidance, market tools and support to ensure compliant and consistent service across territories.

Becoming a Digital Platform Provider

Managing agents are required to conduct thorough due diligence to confirm that the arrangement meets the criteria for appointing a DPP. Once the managing agent is satisfied that all requirements have been fulfilled, the following process should be followed:

Contact the relevant Country Manager to discuss this proposal.

UK only - if you are registering a DPP domiciled in the UK and it fulfils the criteria listed below, then a Country Manager review is not required. You can submit the attestation without providing a Country Manager sign off.

Email coverholders@lloyds.com with the name of DPP and attach a signed copy of the Digital Platform Providers Attestation, attach a copy of the Country Manager’s sign off and if required, any legal opinion.

The Lloyd’s DA team will confirm to the managing agent once the DPP has been added to the internal register. This register will not be published on the Market Directory.

Please note, when a relationship with a DPP ceases, it is the responsibility of the managing agent to notify Lloyd’s to remove the relationship from the register. Please contact coverholders@lloyds.com.

Lloyd’s Expectations of Managing Agents

Should a managing agent choose to enter into this type of agreement with a DPP, Lloyd’s expects robust oversight to be in place. The following criteria must also be met. These criteria may be updated by Lloyd’s from time to time; where that is the case, Lloyd’s will allow managing agents a period of time to update their processes to ensure continued compliance.

Lloyd’s will communicate changes to these criteria through the DA Connect forum, DA Newsletter and update this webpage.

Criteria:

The DPP is given no discretion in the selection of risks, rating or the setting of terms. They must not be able to amend rates/terms/wordings without written instruction from the managing agent or coverholder, as appropriate. Any changes authorised, are applied in the system without the DPP having the ability to modify them again, without further instruction from the managing agent, or coverholder.
The underwriting system for the rating and quoting of policies used by the DPP must be fully automated, with all terms on the system set by the managing agent (or by a coverholder, with the agreement of the managing agent). All contractual policy documentation must be automatically created from the system and the DPP role will be limited to document issuance only (i.e downloading and providing such documentation to the end policyholder).
The managing agent (or its coverholder) must be provided with or be able to access up to date data of policies bound and the performance of the business written. This must be real time or daily access through the online portal.
The managing agent must have a contractual arrangement in place to allow it to control the business being written, including to cease underwriting.
There must be no use of Lloyd's brand on promotional material. This is subject to local, legal and regulatory requirements. Please ensure you speak to the relevant Country Manager.
In all cases, we would expect branding of the policy documentation to be in the name of the coverholder, if there is one in the chain, and/or the managing agent.
The DPP cannot handle claims or complaints.
The DPP is appropriately licenced for the activities they wish to carry out in the relevant territories.
This arrangement is permitted for cross-border business subject to compliance with local law and regulations.

In addition to the above criteria the following points are applicable to managing agent’s oversight:

Each managing agent relationship with a DPP will need to be registered. Please follow the registration process.
The managing agent must ensure their oversight is carried out and aligned with the Principles of doing business at Lloyd’s, including but not limited to, system oversight and testing.
Managing agents should have in place a robust agreement with each DPP, governing the terms of the arrangement. Where a coverholder is in the chain, alongside the binding authority agreement (between the managing agent and the coverholder), the managing agent is expected to be party to any agreement with the DPP, with rights, to enforce the terms. These terms must include, but are not limited to, appropriate service level agreements (SLA’s) for implementing changes to terms or rates or instructions to stop binding policies, including who is expected to turn off the system if the BAA/agreement is cancelled, suspended or non-renewed, i.e. the DPP, coverholder or managing agent.
Other than as set out in this note, Lloyd’s is not prescribing requirements for agreements involving DPPs. Individual managing agents are required to manage the drafting and negotiation of this type of agreement.
Managing Agents are required to notify Lloyd’s and/or (for EU risks) Lloyd’s Europe of any material issue that arises in their dealings with a DPP, via TPMI@lloyds.com. This must also be reported to the Board of the managing agent as soon as possible.

Managing agents are responsible for ensuring that robust oversight and regular review of a DPP is conducted, and that ongoing oversight is maintained. This includes, but is not limited to, verifying that the entity holds appropriate licences.

Lloyd’s Regional Restrictions

In a number of territories, Lloyd’s Local licences mean that any onshore business can only be written by a Lloyd’s approved coverholder and a DPP arrangement may not be permitted.

Territories where DPP arrangements will generally not be permissible include:

Australia
New Zealand
South Africa
US
Canada

Managing agents that would like to appoint a DPP in the above territories, or in any other territory where Lloyd’s has a licence, where you do not already have a DPP arrangement in place; please contact the relevant Country Manager in the first instance or the Delegated Authorities Team. Depending on territory, a managing agent may also be required to seek a legal opinion prior to confirming this arrangement.

Arrangements with DPP should not be set up in territories where Lloyd’s and LIC are not licensed (unless the managing agent can provide evidence of any applicable regulatory exemptions/approvals together with legal advice confirming compliance. In all such cases, the proposal must be referred to Lloyd’s Delegated Authority Team).

Lloyd’s Europe

In addition to the Digital Platform Provider criteria outlined above, DPP’s based in Europe are subject to specific additional requirements for these arrangements:

DPPs must be licensed insurance entities in the EEA.
DPPs must be continuously monitored by the MA.
DPPs must be contractually obliged to follow MA and LIC instructions promptly and within agreed timeframes.
The MA must attest the DPP’s full regulatory compliance.
All business must align with MA and LIC approved business plans.
All DPP business needs to be handled by a seconded underwriter to the LIC UK branch or by the MA EEA service company.
The DPP and/or MA must comply with data requests from LIC.

In the first instance, the managing agent must reach out to the relevant Country Manager and also the LIC DA Team via LloydsEurope.DelegatedAuthority@lloyds.com.

Processing through Velonetic

The following processes are applicable when processing via Velonetic:

Where there is a coverholder in the chain, this should be processed as binder business as normal.
When dealing with a Digital Platform Provider directly there is no specific category for it to be processed under at Velonetic. However, since there is no coverholder involvement, it would be wrong to process it as binding authority business. It can still be processed on a bulked basis but will be classified as open market business and processed through Velonetic as such.