FCA responds to Which? insurance super-complaint
Today, the Financial Conduct Authority (FCA) responded to Which?’s super-complaint on standards in the home and travel insurance markets.
Years of Which? research have exposed widespread failings in how home and travel insurance policies are sold and explained, and also with how claims are then handled. In its report published today, the financial services regulator has said that it agrees, and as a result, will now launch two targeted investigations of these markets.
Here, we explain what’s wrong in home and travel insurance, what we asked the regulator to do when we lodged our complaint in September, and what it’s laid out in response.
What’s wrong with home and travel insurers?
Home and travel insurance firms are among the least likely to pay claims. Extensive research conducted by Which? has also found widespread issues in the levels of service customers receive while claiming – and confusing, vague or potentially unfair clauses in policy terms and conditions. Some of these echo issues that the FCA has itself flagged in its own reviews.
However, we believe the regulator hasn’t been doing enough to tackle the issues in this market. In our complaint, we made three core recommendations.
- We proposed that it urgently intervene to tackle the failure of home and travel insurance firms to comply with their legal obligations, taking enforcement action where necessary.
- We asked it to launch a market study (an in-depth investigation of the market).
- We proposed the FCA and government work together to review consumer protections in insurance.
In its response, the FCA disagrees that it's taken insufficient action to address the problems consumers face, or that it's overlooked market issues in its work to date. But it writes that it's expanding parts of its programme of work in response to our super-complaint.
- Find out more: Which? launches insurance super-complaint
What the FCA will do in response
In the new year, the FCA will now launch two major pieces of work assessing standing issues affecting home and travel insurance customers.
Claims handling
The first is an expansion of its claims handling review, which it had first published this summer. That review flagged concerning evidence of customers receiving poor service when making claims, in part down to insurers outsourcing this part of their service to other companies.
Its new investigation should explore in better detail what’s going wrong for claimants and what will need to be changed to improve standards.
How insurance is sold
The FCA will also investigate how home and travel insurance customers’ outcomes (for example, whether their claims tend to be accepted or rejected) vary depending on how they’ve been sold their insurance.
Which? research from early 2025 found that customers commonly harboured misconceptions about the types of cover typically offered in home and travel insurance policies. Flawed sales and marketing processes – which can oversimplify insurance policies or mask their limitations – can set customers up for failure if they need to claim.
Other measures
The FCA has stated its intent to be more transparent about the enforcement action it takes against insurance firms delivering substandard service, and to work with firms Which? has identified as having vague or potentially unfair terms and conditions.
Since its prior review of home and travel insurers in July, it says it has:
- opened two enforcement cases
- stopped one from doing business until it fixes the problems it's identified
- launched three independent reviews into firms' systems and controls
- made three senior managers agree to fix problems and consider whether redress is due.
'These actions must be the first step'
Rocio Concha, Which? director of policy and advocacy, said:
'Which?’s super-complaint exposed home and travel insurance markets that aren’t working for consumers, and we are pleased that the FCA has taken our concerns seriously. The actions announced today must be the first step towards fundamental reform to ensure these markets work better for consumers.
'The regulator has pledged swift action to review and address problems with customer service, claims handling and how firms sell products, as well as on policy terms and conditions. These issues have been allowed to fester for years, so the FCA must now seize the opportunity to take strong action to stamp out widespread bad practice and issues with how the markets are working.
'Which? expects the FCA to work closely with insurers, comparison sites and consumer groups, but it is essential that any industry-led solutions are accompanied by firm action by the regulator. We will continue to work with the FCA – but also hold the regulator to account to ensure these commitments lead to meaningful change for consumers.'
'We welcome Which? shining a light on issues'
Graeme Reynolds, director of competition and interim director of insurance at the FCA, said: 'We welcome Which? shining a light on issues we identified in home and travel insurance.
'We’ve set out more detail on the action we’ve already taken to fix problems, and we’re expanding our existing workplan to improve the claims process and consumer understanding of their cover.
'We’ll be monitoring consumer outcomes and will continue to hold firms and their senior leaders to account for making improvements, to help build trust and make sure people get fair-value insurance.'
Sign our petition
Over 182,000 people signed our petition calling for change, spreading the word, sharing the real stories and experiences behind the statistics – and ultimately making our super-complaint impossible to dismiss.
We’re beyond grateful, but we’re not stopping here. Click here to find out more about our campaign, or to sign our petition.