PS20/3: Signposting to travel insurance for consumers with medical conditions

Our changes aim to:

• reduce the number of uninsured consumers, who currently face a choice of not travelling or risk having to pay significant costs, including medical bills abroad
• reduce the number of consumers with PEMCs who are significantly overpaying for travel insurance
• reduce the number of consumers who feel frustrated and unable to navigate the market
• increase consumer confidence and trust in the travel insurance market

In addition to signposting, the FCA will be working with stakeholders to try to improve consumer understanding of the travel insurance market, including producing material on PEMCs. This information will help consumers understand the implications of travelling with exclusions, and how factors such as country of travel can impact medical costs and therefore travel insurance premiums.
 

Read PS20/3

What we are changing

Our changes will:

• Require firms to signpost certain consumers with PEMCs to a directory of specialist providers.
• Introduce guidance that firms selling travel insurance policies that exclude PEMCs should tell consumers whether and how these PEMC exclusions can be removed.
• Introduce guidance for firms reminding them to assess the risk from medical conditions and calculate medical condition premiums using reliable information that is relevant to assessing this risk. This will help make sure that consumers are quoted a fair premium which properly covers their circumstances.

Who this applies to

These changes will primarily be of interest to: 

• all firms that offer retail travel insurance, including insurers, Lloyd’s managing agents, intermediaries and appointed representatives
• banks that offer packaged bank accounts which include travel insurance
• insurance industry trade associations
• charities, particularly medical charities
• consumer organisations
• consumers, primarily those with PEMCs

Background to these changes 

Some consumers with PEMCs have problems navigating the market and finding affordable cover for their conditions.

Some are declined cover, only offered cover that excludes their PEMC or offered what they consider to be unaffordable premiums. 

In July 2019, we consulted on new requirements for firms to signpost certain consumers with PEMCs to a directory of travel insurance firms that are able and willing to cover consumers with more serious PEMCs.

We also consulted on new guidance to clarify how we expect firms to treat travel insurance customers with PEMCs.

We received 37 responses to the consultation from a range of stakeholders. These included both mainstream and specialist insurance firms, trade bodies, medical screening companies, charities, consumer organisations and price comparison websites.

This policy statement summarises the feedback we received to this consultation, our response and the final rules and guidance we are making as a result.

Next steps

Firms offering retail travel insurance must implement the new requirements by 5 November 2020. 

Firms will also be required to include the details of the directory on their website within 30 days of becoming aware of the directory going live. We expect the MaPS directory to be completed by Summer 2020.

We will carry out a review approximately 12-18 months post-implementation to assess whether our rules and guidance are delivering our intended outcomes. 

We will also support MaPS’ work to create its directory. This is expected to be completed by Summer 2020. MaPS expect to publish further information about the directory, including details of the application process for firms, later in February.