Tuesday, September 23, 2025
Which? files a super complaint on home and travel insurance
What happened?
After collecting evidence for over a year, Which? has exercised its legal power and filed a super complaint to the Financial Conduct Authority (FCA) about the home and travel insurance markets. The consumer group says there are ongoing problems with claims handling and customer communication, and that despite the FCA being aware of persistent problems, little has been done to resolve them.
Which? claims this amounts to a consistent failure by the FCA to meet its statutory objective to secure 'an appropriate degree of protection for consumers.' It states that it’s acting now because enough is enough; consumers cannot afford to wait longer for action to fix how these markets operate.
What is a super complaint, and who can make one?
A super complaint is a formal route for a designated consumer body to raise a market wide concern. It’s used when a practice is causing significant harm to a large number of consumers. Only organisations approved in law can use it.
Which? last used this power in 2016, when it raised concerns about authorised push payment fraud with the Payment Systems Regulator.
What is the purpose of a super complaint?
The mechanism is designed to surface systemic concerns quickly and requires a time-bound regulatory response - 90 days from the date of receipt. The FCA must assess the evidence, set out findings, and explain any actions it will take within the given timeframe.
What Which? says
Which? highlights three features it says are significantly damaging consumer interests in these markets: poor claims handling, inappropriate sales processes, and a lack of application and enforcement of FCA rules and other law, such as the Consumer Rights Act 2015, Consumer Protection from Unfair Trading Regulations 2008, and the Consumer Insurance Act 2012.
Which? also points to widespread consumer confusion about what’s covered under their home and travel insurance policies. It notes that the upheld rates in this sector sit much lower than in other lines, such as motor insurance.
Why is Which? submitting this super complaint?
In July 2025, the FCA reviewed claims handling of 15 home insurers and 8 travel insurers. It reported “many areas where improvements need to be made” and cited “ongoing customer harm.”
Examples included:
High rejection rates for some storm claims
Use of cash settlements that may leave customers out of pocket
Weak oversight of outsourced handlers and suppliers
Gaps in management information
Only 32% of storm damage claims in the FCA sample in 2024 resulted in a payment.
Which? says the FCA review did not state whether firms had failed to comply with rules, nor did it explain how the problems would be fixed.
They go on to argue that this pattern shows the FCA is not meeting its statutory consumer protection objective and that problems in these markets are being underestimated. On this basis, Which? has used its statutory powers to press for a reset.
Evidence Which? refers to
Which? sets out a ‘wealth of evidence’ in support, including:
The four reports published by them since the launch of their campaign to end consumer harm
Analysis of policy wording conducted with Fairer Finance
Legal analysis of policy wording and information documents by an external barrister
Recent FCA work on claims handling
Where do the acceptance rate figures come from?
The FCA’s General Insurance Value Measures dataset publishes firm-level metrics. This includes claims acceptance rates. The Which? analysis of the 2023 dataset highlights:
Building claims acceptance rates were around 63%
Contents only acceptance rates were 77%
Travel claims acceptance rates were between 79%-82%, depending on cover type
By comparison, motor claims acceptance rates were 99% and lifetime pet claims were 95%
Which? also flags inconsistency between firms.
It notes 18 firms upheld fewer than 75% of combined home and building claims in 2023.
It points to one major provider upholding just 30–35% of building claims.
How this relates to the FCA ICOBS rules
The FCA Insurance Conduct of Business Sourcebook sets expectations that align with the issues raised.
Provide information that is clear, fair and not misleading
Ensure products meet a customer’s demands and needs when proposing a policy
Handle claims promptly and fairly, give reasonable guidance to help a policyholder make a claim, and keep the policyholder informed of progress
Which? reports that these standards have not been met consistently in the home and travel markets.
What the FCA has already set out
The FCA has said it will respond in due course. It has also published materials that frame the context:
A roadmap for retail insurance, setting out findings and actions
A multi firm review of home and travel claims handling with examples of good and poor practice
The industry response
Which? carries a statement from the Association of British Insurers (ABI). It says insurers take their responsibilities incredibly seriously and have always aimed for a clear understanding by the customer, quick and efficient claim handling wherever possible.
The ABI is already working closely with the FCA to ensure good consumer outcomes and wants to engage with Which? to understand their full concerns.
It also points to payouts of over £1.7 billion on more than 300,000 home claims in the first half of this year, and £472 million across more than 500,000 travel claims last year.
The action Which? wants to see
The consumer group says the super complaint should trigger a reset in home and travel insurance, so products serve consumers at some of the difficult points in their lives. It expects this to result in consumers:
Purchasing insurance that better meets their needs and reasonable expectations
Having a better understanding of the relevant limitations of their cover
Experiencing fewer barriers when making claims
Receiving more appropriate support from their insurer, especially in vulnerable circumstances
Having fewer claims rejected
Which? recommendations for the next steps
FCA enforcement: act quickly where firms breach legal obligations, using formal enforcement to secure fixes and deter future breaches
Market study: the FCA should launch a study to address the market dynamics driving poor outcomes in home and travel insurance
Joint review: the FCA and the government should conduct a joint initiative to review consumer protection legal frameworks in insurance and how they are operating in practice, identifying where these need strengthening
What happens next?
Under FCA guidance, the regulator will publish its response within the next 90 days.
Operational leaders should expect questions on claims governance, supplier oversight, the use of cash settlements, and the quality of management information. The FCA documents already point to these control gaps.