At Ding, we talk a lot about scenario-based learning. We use it in our client work, we’ve written white papers about it, and we’ve explored it at length in podcasts and webinars.

But although scenarios are a powerful tool for producing the mindset shift that changes behaviour, clients often wonder how they produce transformation. In this article, we look at how applying scenarios in the insurance industry can help insurers implement the requirements of Consumer Duty placed on them by the Financial Conduct Authority (FCA).

Imagine this situation. A claims handler is on a first-notification call for a home escape-of-water claim. The claimant is co-operative and articulate. Two-thirds of the way through, she mentions in passing that her son has been handling most of the paperwork lately. The handler notices, or doesn’t.

Whether she notices is what Consumer Duty is now measuring. It is also what no policy manual can prepare her for.

The design problem behind the FCA’s claims focus

The FCA’s first Insurance Regulatory Priorities report named improving claims handling and service quality as the sector’s first priority for 2026, alongside expanded supervisory action on outsourced and delegated arrangements. Its 2025 review of home and travel claims found widespread failures of outsourced-handler oversight and inconsistent decision quality. The bar has moved from documented process to demonstrable outcome.

Most claims-handler training is content-based: CII qualifications, product briefings, compliance modules. That work is valuable, and it is not what is failing. What is failing is the capability at the moment of the call — the follow-up question a competent handler asks and a new joiner doesn’t, the pause that changes the direction of a conversation, the reading of a claimant that lets a vulnerability disclosure land.

That capability is a different kind of thing. It cannot be delivered as content, because it does not exist as content. It develops through practice in situations that behave like the real work. The traditional pathway of spending years alongside a senior handler is being eroded on both ends: retirements are accelerating and AI is compressing the routine work that used to be the runway. Firms need a designed replacement.

Scenarios, not role-play

Scenario-based learning for insurance claims and underwriting teams builds back this capability and judgement. A Ding scenario is not a role-play; participants know when they are being coached and adjust their behaviour accordingly. It is not a case study, which is an account of something that has already happened. It is not a compliance vignette with a right answer at the end.

An authentic scenario is an openly fictional situation with real stakes inside it, built around a specific decision a handler will actually face. Information arrives incomplete and out of order. A claimant behaves like a claimant. Other parties – a broker, a loss adjuster, a manager, a family member – have their own priorities. Time constrains what is possible.

Every scenario is designed around a specific moment of judgement, and the design conversation before it is written is about that moment. What is the pause the handler needs to notice. What signal is being suppressed or overplayed. What does a competent handler pick up in the first thirty seconds that a novice takes three minutes to catch, or misses entirely. The scenario is then constructed to make that moment arrive, and to allow it to be repeated.

Repetition is where capability consolidates. A handler encounters the situation, decides, sees the consequence, works through a debrief, then re-enters a related scenario with what they have just learned. Research on how expert performance develops has shown for decades that capability builds through repeated attempts with structured feedback between them, not through exposure alone.

Why this mechanism works

When a handler becomes absorbed in a scenario, attention shifts. They stop performing competence for an assessor and start attending to what the situation needs. That shift is what allows underlying capability to develop rather than be reported on.

Because the scenario is openly constructed, it is possible to pause and examine what happened in ways that would be awkward on a real call. Why did the handler follow the caller down that path? What was the moment the story stopped adding up? These questions become answerable in a way they never are during live QA sampling.

Failure produces feedback rather than a complaint. Handlers try things they wouldn’t attempt on a real call and see what happens: a more direct question, a longer silence, a harder push-back on a broker. The container provides a structurally safe frame around demanding content. The content behaves like real work. That distinction is the design move most training approaches miss, because they treat safety as an experience-wide quality when it is a structural one.

Consumer Duty requires insurers to equip handlers with the skills to read a call. That capability is a design outcome, it’s a product of what a handler is put through, in the year after their CII exam and every year after that.

The firms that keep addressing it by delivering more content will keep failing the same review.

You might also like:

• How fictional scenarios deliver workplace-ready talent
• Using fiction to improve the effectiveness of learning and training
• Why scenarios are more effective than best practice

Download our white paper to find out:

How the regulator’s expectations have moved regarding vulnerability.

How scenario-based training turns abstract policy into rehearsed, repeatable behaviour.

Why you should shift your training focus away from completion and towards developing genuine capability.