In a regulated enterprise, customer communication works when every document family has one accountable business owner. That owner decides what the customer receives and signs off every change. Legal and compliance approve the mandatory text, and your IT or a provider runs production. Failed deliveries are followed up together. A customer communication operating model writes this down per activity, so that a change, a failed run or a regulator’s question always lands with a named person.
Most organisations have the people. What they lack is the line between them.
What does a customer communication operating model cover?
It covers the full life of a communication, from the first draft to the archived copy. In practice that is seven activities:
- Wording and design of the communication.
- Mandatory and legal text: clauses, disclosures, product-specific notices.
- Data and business rules: which customer gets which variant, and why.
- Building and changing templates and journeys.
- Approving a change before it goes live.
- Running production and monitoring delivery across channels.
- Handling failures, complaints and archive requests afterwards.
A document family is the natural unit of ownership: all annual statements, all payment reminders, all policy documents for one product line. Ownership per template is too fine to manage. Ownership per department is too coarse to hold anyone to account.
Who should own customer communication?
The business line that owns the product owns the communication about it. The pension administrator owns the annual pension statement. The collections team owns the payment reminder. Marketing owns the campaign, and only the campaign.
One common alternative tends to fail: IT as owner. Passing every edit through IT is the old way of working. It made sense when changing a letter meant changing code. Modern low-code tools let business owners change their own communications, with IT looking after the platform rather than the wording.
Who does what: in-house platform or managed service?
The owners above stay the same whatever platform you choose. What moves is the work around them. With a platform you run yourself, your IT builds, runs and fixes it. With a managed service, those tasks move to the provider, and your organisation keeps the decisions.
🟦 your organisation · 🟧 the provider
| Activity | Platform you run yourself | Managed service (CCMaaS) |
|---|---|---|
| Content, routine changes and sign-off | 🟦 Business owner | 🟦 Business owner |
| Mandatory and legal text | 🟦 Legal and compliance | 🟦 Legal and compliance |
| Building templates, data and business rules | 🟦 IT | 🟧 Provider, as instructed by the business |
| Running production, upgrades and security | 🟦 IT | 🟧 Provider |
| Monitoring delivery and failed runs | 🟦 IT | 🟦🟧 Both, and the provider can fix issues remotely when needed |
| Archive and audit evidence | 🟦 IT | 🟧 Provider runs it for you, 🟦 the data stays yours and you and your supervisor have access |
Two rules hold in both models:
- Each activity has one accountable owner, even when the provider does the work or the work is shared. If two parties claim it, nobody has it.
- The approver of a change is a named person, recorded per document family, with a named deputy.
Where does ownership usually break down?
In the same five places, across sectors:
- Failed deliveries. The platform reports that a batch of SMS messages was rejected. Nobody owns the customers who received nothing, so nothing happens.
- Business rules. Legal approves the wording of a letter and never sees the data rule that decides who receives it. The wrong customer group gets a correct letter.
- Knowledge in one person. The person who knew why a clause goes to one customer segment changes role, and the reason leaves with them.
- Changes outside the process. A small text change goes straight to production because the approval route takes a week. The audit trail shows a gap exactly where a regulator would look.
- Changes only IT can make. If every wording change needs a developer, the business owner owns the letter on paper only. The platform has to be simple enough for business owners to make routine changes themselves, with the approval route as the safety net and IT free for the work that needs it.
Who signs off when AI drafted the change?
CCM platforms are starting to replace low-code screens with a prompt: a business owner describes the change, and the platform builds the form, the template or the journey step. That makes drafting fast. It does not change who answers for the letter that goes out.
Supervisors take the same view. In its opinion on AI governance and risk management of August 2025, EIOPA expects insurers to apply their existing governance responsibilities to AI systems, including human oversight and record-keeping. Since February 2025, Article 4 of the EU AI Act has also required organisations that deploy AI to make sure their staff understand it well enough to use it.
For customer communication, that translates into four conditions:
- AI produces a draft, never a live change. The draft goes through the same approval route as a change made by hand.
- The approver is the business owner of that document family. AI does not create a new owner, and it should not create a shortcut around the existing one.
- The approver sees exactly what changed. New and changed elements shown side by side with the live version, plus a note of what the AI looked at.
- The approval is kept. Who approved, when, which version. That record is the audit evidence.
Eclipse applies the same principle as AI assistance comes into its platform: AI proposes a draft, and a named person decides.
The effect on the operating model is that the bottleneck moves. Building gets faster, so approving becomes the step that decides speed and quality. Organisations that have named owners per document family absorb that easily. Organisations that have not will find the gap faster.
How a managed service like CCMaaS can help
A managed service, also called CCM as a service (CCMaaS), takes over the work that sits furthest from the business: building templates and making technical changes, running production, upgrades and security, monitoring delivery, and running the archive on your behalf. That leaves your organisation with the part only it can do: deciding what customers receive and approving every change.
It helps the operating model in three ways:
- Fewer roles to staff. You no longer need your own platform team for a system that is not your core product.
- Approval routes built in. A good provider sets up the approver per document family in the platform, so every change follows the agreed approval route rather than email.
- Business owners in control. Business owners make routine content changes themselves, in intuitive low-code tools, while the provider handles the technical work behind them.
Three things stay with you in any model: one named owner per document family, with a deputy; the approval itself; and a decision on how AI-drafted changes are approved before anyone uses AI in production. Check the contract for the rest, in particular who contacts customers after a failed delivery and how you and your supervisor reach the archive.
Frequently asked questions
What is a customer communication operating model?
It is the agreement on who decides, builds, approves, runs and follows up each customer communication. It is usually written down as a table of activities and owners per document family, and it is what makes approval routes and audit trails meaningful.
Should IT or the business own customer communication?
The business line that owns the product owns the communication about it. IT, or a managed service provider, is responsible for running the platform and production. Splitting it this way gives each side decisions it is equipped to make.
Who approves an AI-generated letter or template?
The same person who approves a change made by hand: the business owner of that document family, with legal and compliance signing off mandatory text. AI can help draft; a person approves.
How many approvers does a change need?
One is usually sufficient: the business owner of the document family. Legal and compliance sign as well only when mandatory text or a disclosure is touched. More signatures tend to slow changes down without making them safer.
Does a managed CCM provider decide what goes in my letters?
No. The business owner decides what customers receive and signs off every change. The provider implements as instructed and runs the platform.
Do I have to send every content change to the CCMaaS provider?
No. On a modern platform you make content changes yourself, in intuitive low-code tools, and the provider supports you with the technical work behind them.
Related: CCM, CRM and marketing automation: who does what?
If you are working out who signs off what, especially now AI is entering the build step, we are glad to compare notes.