Step-up confirmation
Step-up confirmation is the requirement, defined in the A2A Consent, Authority and Scopes standard, that every Class 2 action - creating or changing a contract, or moving money - must receive a fresh, human-present confirmation at the point of action. The agent prepares the full transaction; the customer confirms the premium, key exclusions, data consents, and authority cap before the bind proceeds. It is the default conformance mode under Tier A of the A2A protocol.
What is step-up confirmation?
Step-up confirmation is the bridge between what an AI agent can prepare autonomously and what it is permitted to execute without explicit human approval. In the A2A action risk class model, Class 0 (read) and Class 1 (quote) actions require no step-up. Class 2 (transact) and Class 3 (claim) require it by default under Tier A.
The standard specifies that step-up confirmation must include: the premium or premium change; the key exclusions surfaced; the data and enrichment consents being exercised; and the authority cap being used. The customer's human-present signing of this confirmation, through whatever mechanism the surface provides, is the legal evidence that the customer consciously authorised the action.
The A2A standard specifies that the compliance rail does not need to own the confirmation UI. The standard defines the required content of the confirmation; the surface - ChatGPT, Claude, or another AI platform - provides the human-present signing mechanism. This is how step-up operates inside a general-purpose AI assistant: the platform handles the UI; the A2A standard defines what must be in it.
The alternative to step-up is Tier B, or delegated authority, in which a customer pre-authorises an agent to act autonomously within defined caps. Tier B is an opt-in mode requiring stronger agent identity verification and heavier conformance obligations than Tier A.
Why does step-up confirmation matter for insurance?
Step-up confirmation is the structural safeguard that prevents agentic insurance from becoming fully automated insurance without customer awareness. It preserves the customer's right to pause, review, and refuse at the moment that matters: immediately before money moves and a contract is created.
From a regulatory perspective, step-up confirmation is the mechanism that satisfies Consumer Duty requirements around informed decision-making in an agentic context. It is what allows Tier A agents to operate without bespoke FCA authorisation for autonomous action.
Related terms
The transaction flow in which step-up confirmation is Stage 7.
The Rail that enforces the step-up gate and records the confirmation.
The standard that defines step-up confirmation in its Consent and Authority section.
The distribution model that requires step-up as a safety mechanism.
Source
Step-up confirmation is defined in the Consent, Authority and Scopes standard, Tier A conformance requirements.
Last updated 2026-06-18
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