The FCA has published Consultation Paper CP26/33 proposing (for now) two minor changes to value measures data reporting and providing useful insight into the FCA’s and industry views in relation to general insurance value measures data and reporting. The FCA introduced value measures rules in 2021, following its 2014 general insurance add-ons market study and a pilot scheme run from 2016 to 2020. Firms report annual data on a range of value measures such as claims frequency, claims acceptance rates, average claim pay-outs and claims complaints, and the FCA publishes some of this data by firm and product.
The FCA has completed a post-implementation review of the general insurance value measures rules, published as part of the Consultation Paper. This review highlights data issues the FCA is tackling (for example, the inconsistencies in how firms report claims acceptance data for home insurance). The review found the rules have improved transparency and helped firms meet fair value requirements, but reporting inconsistencies make the data harder to use and compare.
- The two reporting requirements that are proposed for removal are:
- the amount that the top 2% of claim pay-outs are above; and
- the names of firms’ five largest distribution arrangements for each product.
- The FCA proposes that these changes take effect for 2026 and 2027 data submissions on a transitional, optional basis, becoming mandatory from the 2028 reporting year (due to be submitted in 2029).
- The FCA expects to consult on wider changes to its value measures reporting rules in 2027. This may include more frequent publication of value measures data.
- The regulator has admitted it needs to improve at publishing the data on a ‘timely basis’ in future – firms provide their data by the end of February, but the FCA has not published it until July (2025), August (2023), September (2022) or October (2024).
- The FCA is inviting comments on the proposals by 9th October 2026. Firms can respond using the online response form, or by e-mail cp26-33@fca.org.uk.
- Following this consultation, the FCA expects to consult on wider changes to the value measures rules in the first half of 2027.
Survey results
- Firms mostly use value measures in internal governance, peer benchmarking and as an input into fair value assessments, having embedded them into their own product governance frameworks.
- Feedback from stakeholders suggests value measures data has been successful in improving consumer outcomes; fewer consumers buying unsuitable general insurance products, less demand for ‘low quality’ products, and better product value. However, certain firms reported that the data’s role had become less central since the introduction of wider fair value rules.
- The majority of firms polled say that value measures data helps improve transparency and competition.
- The biggest impact is felt to be from claims acceptance rates and claims complaints as a percentage of claims.
- The FCA has noted the point on multi-year products, a reason why the value measures data for GAP Insurance is perhaps skewed.
- There is reference to aligning the products reported on in value measures with those in the new complaints reporting *(paragraph 6.18)
- 50% of firms say the reporting rules are unclear, leading to inconsistency in reporting amongst the (174) firms reporting this data. This led to the FCA having to query the returns of 32 of those firms.
- The FCA’s definition of a ‘claim’ is too broad – e.g., attempted claims below the policy excess, or mere enquiries from policyholders as to whether something is covered or not.
- Use of value measures data by consumer associations and the financial media has been generally low. Grouping data by insurer rather than consumer-facing brands has not helped.
- The FCA thinks AI will be accessing and using the value measures data to help inform its response to consumers’ insurance questions. That being the case, it is perhaps vital that there is clarity in what to report, and accuracy in the published details
- The FCA will continue to engage with consumer associations to get their input – Which? and Fairer Finance were specifically mentioned.
- Geopolitical instability and related inflationary pressures may have affected claims costs and supply chains, particularly in the travel insurance sector (the value measures data for travel insurance has, in UKGI Group Consultancies’ experience, never appeared accurate).
- The FCA states that “Claims outcomes have become a greater focus for us”.
- The FCA has recognised industry issues with the differentiation between add-ons and standalone products.