Payment protection insurance One of the most significant conduct issues affecting the United Kingdom insurance sector has been the mis selling of
payment protection insurance (PPI). PPI policies were widely sold alongside loans, credit cards and other credit products to cover repayments if the borrower became unable to pay because of illness, unemployment or death. Regulators and courts found that, in many cases, PPI had been sold to customers who did not need it or could not claim on it, and that high levels of undisclosed commission had been added to premiums. The
Financial Conduct Authority introduced rules and guidance to ensure that firms handled PPI complaints fairly and, following a publicity campaign, set a deadline of 29 August 2019 for consumers to complain to the firms that sold the policies. FCA data shows that between January 2011 and December 2019 firms paid about £38.3 billion in PPI refunds and compensation to customers, making it the largest consumer redress exercise in United Kingdom financial services. The PPI experience influenced later reforms to product governance, disclosure and redress arrangements for insurance and other retail financial products.
General insurance pricing and loyalty penalties The pricing of retail general insurance, particularly home and motor policies, has been a long running area of scrutiny. An FCA market study into general insurance pricing practices found that some insurers charged significantly higher renewal premiums to longstanding customers than to new customers with a similar risk profile, a practice often referred to as "price walking" or the "loyalty penalty". In May 2021 the FCA confirmed a package of remedies, including new rules requiring firms to ensure that renewal quotes for home and motor insurance customers are no higher than the equivalent new business price for the same firm, as well as measures to improve product value and communications. These changes, which took effect from January 2022, are intended to reduce cross subsidisation between customers, strengthen competition and support fair value in line with the FCA's wider
Consumer Duty and fair value initiatives.
Add-on insurance and value concerns The sale of insurance as an add on to another product has raised concerns. In 2014 the FCA's general insurance add ons market study found that competition in add on markets was often not working well for consumers and that many customers were paying too much for products that offered poor value or did not meet their needs. The study highlighted issues in several add on lines, including travel, gadget, home emergency, personal accident and
guaranteed asset protection (GAP) insurance. Following this work the FCA introduced remedies such as banning pre ticked boxes for add ons, requiring clearer information on price and coverage, and developing value measures and reporting requirements to improve transparency. In 2024 the FCA reported that GAP insurance in particular was often not providing fair value and required a number of firms to pause sales while they improved their value assessments and product design.
Premium finance and affordability Many policyholders pay for motor and home insurance in monthly instalments using premium finance arrangements. FCA research has found that these arrangements can involve relatively high annual percentage rates and fees compared with other forms of credit and that customers who choose, or are forced by affordability, to pay monthly can end up paying significantly more overall than those who pay annually. In some cases regulators and commentators have raised concerns about "double dipping", where customers who opt to pay monthly are charged both higher underlying premiums and interest on the financed amount. The FCA's premium finance market study, launched in 2024, is examining whether consumers are receiving fair value from premium finance and how firms should manage distribution, pricing and disclosure.
Business interruption insurance and COVID-19 During the
COVID-19 pandemic, many businesses in the United Kingdom made claims under business interruption insurance policies for losses arising from public health restrictions. There was significant uncertainty and dispute over whether standard policy wordings covered losses arising from the pandemic. To provide clarity, the FCA brought a test case under the Financial Markets Test Case Scheme. On 15 January 2021 the
Supreme Court substantially allowed the FCA's appeals and dismissed insurers' appeals in
FCA v Arch Insurance (UK) Ltd and others [2021] UKSC 1, confirming that many non damage business interruption policies provided cover for COVID 19 related losses. The judgment and subsequent regulatory guidance required insurers to reassess and pay valid claims more quickly and provided guidance on how policyholders could evidence the presence of coronavirus in the relevant area. The test case is regarded as a significant example of the use of a representative action to resolve widespread uncertainty in insurance coverage.
Motor injury claims and whiplash reforms Motor insurance claims costs in the United Kingdom have been influenced by reforms to low value road traffic personal injury claims, particularly those involving whiplash. The Civil Liability Act 2018 and related secondary legislation introduced a statutory definition of whiplash injury, a tariff of fixed damages for whiplash and minor psychological injuries, a higher small claims limit for most road traffic injury claims, and a ban on settling whiplash claims without medical evidence. Since 31 May 2021 most straightforward low value road traffic injury claims have been expected to be made through the Official Injury Claim online portal, which is intended for use by unrepresented claimants as well as by legal professionals. Parliament has considered the impact of these reforms on claim numbers, compensation levels, access to justice and motor insurance premiums. Insurers have argued that the reforms should reduce claims costs and help contain premiums, while some consumer and claimant groups have expressed concern about barriers for injured people using the system.
Personal injury discount rate Very serious motor and liability claims in the United Kingdom are affected by the personal injury discount rate, sometimes called the Ogden rate, which is used by courts to calculate lump-sum damages for future losses. Following a statutory review, the Lord Chancellor announced in December 2024 that the rate for England and Wales would increase from minus 0.25 percent to plus 0.5 percent with effect from 11 January 2025. Commentary by actuarial and legal firms suggests that the increase in the discount rate is expected to reduce the cost of very large personal injury claims compared with the previous rate and may therefore ease some pressure on motor and liability insurance premiums, although other cost drivers remain important.
Other issues The United Kingdom insurance sector has been involved in other conduct issues and redress exercises, including concerns about claims handling, value for money and the clarity of policy wordings. These have been addressed through enforcement action, thematic work and wider regulatory initiatives such as the Consumer Duty, which requires firms to demonstrate that insurance products provide fair value and good outcomes for customers across their lifecycle. In the wider retail financial services market, large scale redress programmes have also been proposed for issues such as mis sold motor finance commission arrangements, which have been compared in scale to the PPI redress exercise, although these relate to consumer credit rather than insurance contracts. ==See also==