Claim Passport® Certificate Standard
An evidential standard for portfolio after the event and bulk consumer claims risk. Six gates, four verdicts, one dated artefact per file.
First issued 15 November 2025. This edition, CPCS / 2026.11.
What is actually being underwritten
Cover written over a book of consumer claims is priced on volume, claim type and expected success. It is rarely priced on whether each file can evidence itself. Those are different risks. A claim can be good in law and still be worthless to an insurer if the claimant cannot be shown to have been lawfully obtained, properly informed and validly instructed.
Origination is the point where that evidence is either created or lost, and it usually sits with a party the insurer never contracts with and never sees. This standard tests it.
Why this sits on the underwriting side, not the compliance side
Every position below carries its classification. Nothing here is asserted against any named firm, funder or insurer.
The regulator has already measured the gap. The SRA High Volume Consumer Claims thematic review, published August 2025, covered 129 firms holding more than 2.4 million live claims, with visits to 25 firms. Only 11 of the 25 could evidence that required client care information had been shared with all claimants. Poor compliance with after the event insurance obligations was named expressly. As at 31 July 2025 there were 95 investigations open relating to 76 firms.
Funding arrangements are concentrated and largely unexamined. Of the 129 firms surveyed, 30 used third party litigation funding totalling around £200 million, across approximately 42 funders, of which only seven were members of the Association of Litigation Funders.
Commission inside the premium is disclosable and has been disclosed by order. In Edwards and Raubenheimer v Slater and Gordon [2022] EWHC 1091 (QB) the court ordered the firm to answer Part 18 requests on commissions received on after the event premiums deducted from damages. The evidential root came from the insurer's administrators, who confirmed a £258 premium comprising, among other elements, a £30 claims handling commission and a £176 claims fund contribution. The two actions covered 140 and 144 claimants.
The fiduciary route survived the Supreme Court, and it points at the firm. The judgment of 1 August 2025 in the motor commission appeals held that undisclosed commission alone creates no liability at common law or in equity, and that a fiduciary relationship must be established. A dealer was held not to owe one. A solicitor is the paradigm fiduciary category, so the route closed against intermediaries remains open against firms.
Premium structures are moving toward open court records. Administrators of a collapsed high volume claims firm are reported to be pursuing an action of approximately £19.5 million against an after the event insurer. Proceedings of that kind place commission and premium structures into pleadings, where they become citable rather than inferred.
Process evidence is not a defence on origination. Article 5(2) of the UK GDPR places the burden on the controller to demonstrate valid consent for each individual. In the enforcement action of 4 July 2023, the soft opt in was rejected notwithstanding the firm's processes, with a £120,000 penalty and an enforcement notice covering 4,046,947 messages. Enforcement activity in this sector continued through July 2026.
Cell level capacity has been tested in court and did not hold. In a 2020 case in the United States District Court for the Eastern District of Louisiana, an obligee claimed on a bond issued by a Nevada protected cell captive. The captive did not honour it, on the basis that no valid bond had ever been issued, and argued in the proceedings that only one numbered cell could be liable and that the cell in question had no members at all. Cover written through a numbered cell is cover written against that cell, and the cell can be argued to be empty.
The placing chain itself is now failing. Two litigation funders financing volume consumer claims entered administration in the four months to July 2026, one of them carrying a loan book of around £249 million across more than 300,000 cases and a group company at the same address, both secured by the same lender on the same day. Administrators of that kind take file audit rights over the funded books and examine the conduct of associated parties and introducers.
The exposures are correlated and are currently rated as if they were not. A book carrying an unevidenced origination trail is the same book most likely to face fiduciary and data claims from its own former clients. Where cover is written over that book, the insurer is exposed twice to one defect through two different mechanisms, on a single rating.
Six gates, one artefact each
A file is tested against six gates. Each gate is satisfied by a specific artefact taken from source records. Attestation by the firm is not an artefact.
Provenance
How this claimant became a claimant, and through whom. The originating party is identified by name, the acquisition route is recorded, and the batch is dated.
Artefact Origination record naming the introducing party, the route and the date.
Consent
The lawful basis on which the claimant was first contacted, evidenced per file rather than per campaign. A record of the claimant's response evidences the response, not the consent that preceded it.
Artefact Per file consent record with source, wording, timestamp and lawful basis.
Identity
That the claimant is a real, identified person, verified independently of the party who introduced them.
Artefact Identity verification result held outside the originator's system.
Instruction
That the claimant instructed this firm on this claim, on terms they were given, and that the retainer and funding arrangement were explained before signature.
Artefact Executed retainer with the client care and funding disclosure served at the time.
Exclusivity
That the same claim is not already advanced elsewhere. A claim advanced through another party surfaces regardless of who advanced it, who originated it or which entity holds it now, with a confidence score and supporting evidence attached. The detection method is proprietary and is withheld deliberately.
Artefact Duplication result with confidence score and evidence reference.
Currency
That the file is live and the claimant is contactable and still instructing, as at a stated date. Currency decays, so it is reported as at a date and never in general.
Artefact Dated contact and status test against the current record.
Four verdicts
Certified
Every gate satisfied by artefact. The file can evidence itself today.
Qualified
Every gate satisfied, with a recorded limitation on one or more artefacts. The limitation travels with the verdict.
Unevidenced
The artefact does not exist or cannot be produced. The standard reports the absence rather than manufacturing a substitute.
Failed
The artefact exists and contradicts the position claimed for the file.
Verdicts are issued at file level and aggregated to a cohort position: certified percentage, failure pattern by gate, failure pattern by originating party, and an exception register.
Where the cover actually sits
Bulk consumer claims are not always covered by a UK authorised insurer. Some volume is written through offshore protected cell captives and issued to the claimant as a bond rather than a policy, with the arrangement placed by an intermediary rather than by the firm direct.
Client packs of that kind state in terms that the bond falls within no compensation scheme in the United Kingdom or elsewhere, with the claimant's protection resting on reinsurance behind the cell. That is a lawful structure and it is disclosed. It is also a different risk from an authorised policy, and it is frequently described upstream in the same language.
Three things follow, and none of them is theoretical. Cover placed through a numbered cell is cover against that cell alone, and a cell can hold nothing. The company named to the claimant as arranging the bond may be a dormant shell rather than an authorised intermediary, in which case the consumer facing document names a party that could not lawfully have done what it is described as doing. And where the intermediary or the funder behind the premium enters administration, the placing chain sits inside an insolvency, with an administrator holding file audit rights over the same book.
Why capacity is part of the file
Where the paper behind a cohort is a captive bond, validity of the underlying file carries more weight, not less, because there is no scheme sitting behind a failure to respond. Certification records what the claimant was actually issued, through whom, under what cell or policy number, and whether that party held any permission to arrange it. A cohort's capacity position is then known at inception rather than discovered at notification.
What this is not
- Not a merits opinion. The standard tests whether a file can evidence itself. It expresses no view on whether the claim succeeds.
- Not a remediation exercise. Where the artefact never existed, the standard reports its absence rather than creating it.
- Not dependent on the firm's word. Every gate tests against source records. Attestation is not an artefact.
- Not a keystroke audit. An audit trail records what a handler typed. It cannot reach an event that happened before the file was opened.
- Not a compliance sign off. A sign off approves material at a point in time. Certification is scored, dated, reproducible and issued per file.
The time limit nobody prices
Provenance evidence sits upstream with the originating party. Where an originating entity is wound up, restructured or dissolved, the record of how a claimant became a claimant goes with it.
Certification carried out while the chain is intact is recoverable. The same exercise attempted afterwards is not, at any price.
Four points where it attaches to a policy
- Condition precedentCover attaches only to files certified as at a stated date. Unevidenced and failed files do not attach and attract no premium.
- Continuing warrantyThe insured warrants the records were complete and unaltered at the certification date, with avoidance running to the batch and the originating party rather than the single file.
- Premium differentiationThe certified percentage becomes a rating input. A book that can evidence itself pays less than one that cannot, and the difference is measured rather than assumed.
- Claims validationOn notification, the certificate for the underlying file and the relevant exception register entry are producible. Where no certificate exists for that file, the position is known before indemnity is considered.
Model wording giving effect to all four is set out at Schedule 1.
How it runs
- Read only ingestion. The standard is applied against the firm's own case management and origination records in place. No book is transferred and no claimant data leaves the insured's environment.
- Scoped first run. A defined cohort establishes the certified percentage and the failure pattern before the book is certified in full. It is a paid scoped engagement, not a trial.
- Full run. The certification is applied at book scale, producing file level verdicts, the cohort position and the exception register.
- Re test. Currency decays. The standard is re run at the interval the policy specifies, at clause 4 of Schedule 1, and the certified percentage is reported as at a date.
Certification is held independently of the case management layer. Where the party that originated the volume is also the supplier of the system holding the origination records, the record and its author trace back to one party. That is a qualified position in itself, regardless of whether anything is wrong with the data, and it is resolved only by evidence accrued and held outside that party's control.
Every position produced under this standard is classified as verified, reported or assessment, and the classification travels with the artefact.
Certified Origination Endorsement
Model wording, issued for underwriter consideration. It is not legal advice, insurance advice or settled market wording. Square brackets are the underwriter's variables.
Attaching to and forming part of Policy T&C. Applicable to portfolio after the event and bulk consumer claims cover.
Endorsement drafting pack Variables, clause by clause reasoning, rating framework and placement checklist. Access code required.1. Definitions
1.1 Certificate Standard means the Claim Passport Certificate Standard as published at the Inception Date, comprising the six certification gates of provenance, consent, identity, instruction, exclusivity and currency. 1.2 Certificate means a dated artefact issued under the Certificate Standard recording, at file level and at cohort level, a verdict of certified, qualified, unevidenced or failed against each gate. 1.3 Certified File means a Claim in respect of which a Certificate records a verdict of certified or qualified against all six gates. 1.4 Certified Percentage means the proportion of the Cohort constituted by Certified Files, expressed as at the Certification Date. 1.5 Certification Date means the date on which the Certificate is issued. A Certificate speaks only as at its Certification Date. 1.6 Cohort means the body of Claims declared to Insurers under this Policy. 1.7 Originator means any party by whom or through whom a Claim was introduced, generated, purchased or otherwise acquired, whether or not that party is the Insured. 1.8 Exception Register means the schedule of non certified files produced with the Certificate, stated by gate and by Originator.2. Condition precedent to attachment
2.1 It is a condition precedent to the attachment of cover in respect of any Claim that the Claim is a Certified File as at the Certification Date, and that the Certificate has been issued no earlier than [90] days before the date the Claim is declared to Insurers. 2.2 Claims recorded as unevidenced or failed against any gate do not attach and attract no premium.3. Continuing warranty
3.1 The Insured warrants that the records against which each Certificate was issued were, at the Certification Date, complete and unaltered, and that no artefact was created, reconstructed or supplied for the purpose of certification which did not exist at the time of the event it evidences. 3.2 Breach of clause 3.1 in respect of any Claim entitles Insurers to avoid cover in respect of that Claim ab initio, and in respect of every Claim originating from the same Originator and the same batch.4. Currency and re test
4.1 The Certificate Standard shall be re run on the Cohort at intervals of not more than [12] months, and on each renewal of this Policy. 4.2 Where a re test returns a Certified Percentage lower than that declared at inception by more than [5] percentage points, the Insured shall notify Insurers within [14] days, and Insurers may re rate the Cohort from the date of the re test.5. Premium
5.1 Premium is rated by reference to the Certified Percentage declared at inception, at the scale set out in the Schedule. 5.2 Where the declared Certified Percentage is subsequently found to have been overstated, premium shall be adjusted to the rate applicable to the corrected figure, and the difference shall be payable whether or not any claim has been notified.6. Claims validation
6.1 On notification of any claim under this Policy, Insurers may require production of the Certificate applicable to the underlying Claim and the relevant entry in the Exception Register. 6.2 Where no Certificate can be produced for the underlying Claim, no indemnity is payable in respect of it.7. Originator concentration
7.1 The Insured shall disclose the proportion of the Cohort attributable to each Originator, and shall notify Insurers within [30] days where any single Originator comes to account for more than [40] per cent of the Cohort. 7.2 Where the Originator is also the supplier of the case management system holding the origination records, the Insured shall disclose that fact, and certification shall be carried out and held independently of that system.8. Access
8.1 Certification is carried out on a read only basis against the Insured's own records in place. No claimant data leaves the Insured's environment and no book is transferred. 8.2 The Insured shall procure such access as is necessary for certification and re test to be carried out, and failure to do so suspends cover in respect of the affected part of the Cohort.9. Capacity and intermediary continuity
9.1 The Insured shall disclose, in respect of every Claim in the Cohort, the identity of the risk carrier, the policy or bond reference and, where cover is placed through a protected cell, series or segregated account, the identity of that cell. 9.2 The Insured shall disclose the identity of every party by whom the cover was arranged, introduced or administered, and shall confirm that each such party held, at the date of placing, the permissions required to carry on that activity. 9.3 Where any carrier, cell, intermediary or premium funder in the chain enters administration, liquidation, provisional liquidation or any equivalent process, the Insured shall notify Insurers within [14] days, identify the affected part of the Cohort, and state whether an officeholder has taken or asserted rights of access, audit or assignment over the underlying files. 9.4 Where cover in respect of any Claim is placed outside any statutory compensation scheme, that fact shall be disclosed at inception and recorded in the Certificate. 9.5 Failure to disclose under this clause entitles Insurers to treat the affected Claims as unevidenced for the purposes of clause 2.10. Classification
10.1 Every position recorded in a Certificate is classified as verified, reported or assessment, and the classification travels with the artefact.11. Priority
11.1 Where this Endorsement conflicts with the Policy wording, this Endorsement prevails. All other terms, conditions and exclusions remain unaltered.Commissioning a certification
Certification is not a review, an audit or a written opinion. It is a run on the Claim Passport engine. The book is onboarded onto the platform, the six gates are applied to every file at book scale, and each file leaves with its own dated artefact held independently of the case management layer.
What is being bought is the engine and the accrual behind it: multi point data accrual for provenance and duplication, identity resolution held outside the originator's system, dated currency testing, and the classification discipline that makes the output usable by a reinsurer, an auditor or an officeholder. The detection method is proprietary and is withheld deliberately.
Scope is agreed before anything runs. A cohort that cannot be accessed at file level cannot be certified, and that is established at scoping rather than discovered halfway through a book.
Enquiries
Underwriting, managing general agent, broker and reinsurance enquiries. Click the address to open a pre filled email, or send the form below.
Thank you
Your email application has opened with the details filled in. Send that message and a reply will come from admin@occ-uk.com within one working day.
Run on the Wolf AI certification engine