The Dutch Authority for the Financial Markets (AFM) has published review findings calling on insurers to distinguish customer interests from customer satisfaction and assess whether their policies and organizational culture protect customers in practice. Insurers still regularly fail to make an explicit distinction between the two concepts in their policies. Satisfying a customer does not necessarily mean serving their interests. For example, additional questions during underwriting or claims handling may be unpopular but necessary to reach a careful and appropriate outcome. Many insurers have policies covering customer treatment, organizational culture and artificial intelligence (AI). Monitoring should go beyond counting customers or AI applications to establish whether those policies are implemented as intended. Where a policy requires employees to review AI outputs and correct or override them when necessary, insurers should check whether this happens. Evaluation should then establish whether those reviews adequately reduce customer risks and deliver the intended outcomes, while identifying unintended effects such as unnecessary delays. Findings should inform concrete improvements and be discussed at the appropriate organizational level. Assessing whether organizational culture encourages employees to act in customers’ interests remains a challenge, despite examples of clear behavioral expectations and leadership supporting openness. Employee surveys can examine whether customer interests genuinely influence decisions and whether staff have room to discuss dilemmas, mistakes and dissenting views. Performance reviews can also explicitly address conduct that serves customer interests.
Dutch Authority for the Financial Markets calls on insurers to distinguish customer interests from customer satisfaction
The Dutch Authority for the Financial Markets has urged insurers to separate customer interests from customer satisfaction after finding that policies still regularly lack an explicit distinction. Insurers should test whether policies are implemented and effective, including whether human review of AI outputs reduces customer risks. Assessing whether organizational culture supports decisions in customers’ interests also remains a challenge.