General insurance value measures

We identified poor product value as an area of harm in general insurance and have introduced reporting rules to address this.

In our General Insurance (GI) add-ons market study (MS14/1) we identified poor product value as an area of harm in general insurance. This has been caused by ineffective competition between providers of insurance products and a lack of common measures of value. 

To help address this we introduced new rules to report and publish data on value measures, as set out in our Policy Statement (PS20/9)

Firms will be required to:

  • report GI value measures data including claims frequencies, claims acceptance rates, average claim pay-outs and claims complaints as a % of claims; and
  • ensure that products offer fair value to customers in the target market.

Reporting responsibility

In the table below we have, with reference to the product structure, set out which firm is responsible for submitting the value measures data. Depending on the firm’s business model and arrangements, there could be a need to obtain data and information from other firms. As a reminder, the firm responsible for value measures reporting is set out in SUP 16.27.7R and SUP 16.27.8R. These provisions must be considered together with SUP 16.27.9R. 

Product Structure Who reports the value measures information in relation to that business
One contract of insurance and one insurer underwriting the cover included in that contract.  The firm set out in SUP 16.27.8R. 

A SUP16.27.9R (1) scenario: 

One contract of insurance and more than one insurer underwriting parts of the cover in that contract of insurance (these could, for example, be optional extras and cover extensions). 

The firm set out in SUP 16.27.8R but if more than one insurer, then the insurer responsible for the value measures report is the insurer underwriting the main part of the cover (and in the event of any doubt, the first part of the cover recorded in the policy).  

The product category under which to report the ‘optional extras’ value measures data will be the main part of the cover. For example, home emergency could be an optional extra within a home insurance contract of insurance and will be reported under the home insurance product category. 

Please note the exception in SUP 16.27.9R(2).

Two or more contracts of insurance bundled together.  

For example, a policy booklet can include a main contract and add-on policy/ policies. 

One of the contracts in a ‘bundle’ could also contain, for example, optional extras and for that contract the above row also needs to be taken into account. 

The business in relation to these contracts of insurance are reported separately by the firm set out in SUP 16.27.8R.  

  1. One firm could be responsible for the reporting in relation to all those contracts of insurance (for example the insurer underwrites all those contracts in the bundle), then that firm needs to report on the business in relation to all those contract (using the relevant product categories set out in SUP 16 Annex 48R). But also see (3) below. 
  2. There could be different firms responsible for the various contracts of insurance in the bundle (for example they are effected by different insurers), then the business in relation to these contracts of insurance will be reported on separately by the separate responsible firms. Also see (3) below. 
  3. If the bundle contains a contract of insurance which contains, for example optional extras, then the responsible firm is the one as explained in the row above (ie the insurer underwriting the main part of the cover). But also take into account the exception in SUP 16.27.9R(2). 

Reporting for legal expenses and vehicle breakdown products

For all legal expenses and vehicle breakdown products, firms are not required to report data for the following metrics: 

  • average claims pay-out;
  • total claims pay-out cost; and
  • the amount that the top 2% of claim pay-outs are above.

When completing the first value measures data submission in RegData, firms can enter £0 into the reporting form cells for these three metrics for all legal expenses and vehicle breakdown products.

When you need to report

The rules came into force on 1 July 2021. A firm’s first report will be for the 6-month period covering 1 July 2021 to 31 December 2021 and will be due by 28 February 2022. Subsequent reporting must be submitted annually thereafter by 28 February for the previous calendar year.  

Firms will need to submit the reports via RegData, which is our new data collection platform for gathering regulatory data from firms.

We will publish some elements of this data to further incentivise firms to improve their products. This data also provides us with valuable information when we’re supervising firms. 

Page updates

15/02/2022: Information added Reporting for legal expenses and vehicle breakdown products
11/01/2022: Information added Information on reporting responsibility added.