Which? Files a super-complaint with the FCA.
Which? has filed a formal super-complaint with the Financial Conduct Authority (FCA) over serious concerns about how the home and travel insurance markets are operating. They claim that these sectors consistently show low claims acceptance rates and poor customer outcomes, leaving many people without adequate support when they need it most.
Keep reading to find out what’s going wrong and what insurers need to do now to stay on the right side of regulation.
The super-complaint was submitted on the 23rd September 2025. A response is expected from the FCA by the 22nd December.
What is a super-complaint?
A super-complaint is a formal process initiated by a designated consumer body and submitted to a regulator. It addresses systemic issues in a market that significantly harm the interests of its consumers. It’s not about individual grievances, but rather patterns of behaviour or structural problems that affect many people.
This case is particularly important because it’s the first time Which? has used its statutory powers since 2016. It reflects a growing frustration that repeated reviews have identified “Little evidence that the FCA has taken meaningful action to address the many persistent problems that exist in these markets.”
What's behind the complaint?
Submitted on the 23rd September 2025, Which?’s super-complaint is supported by extensive research. It suggests there are three systemic issues:
- Poor claims handling. Only 63% of buildings insurance and 81% of travel insurance claims were accepted, compared to 99% for motor insurance. Consumers report delays, confusing rejections, and distressing experiences that worsen already difficult situations.
- Inappropriate sales practices. Policies are shown to have been sold with unclear or misleading terms. Consumers frequently report that they discover exclusions only after making a claim. Some vulnerable customers have experienced discriminatory pricing or outright rejection.
- Regulatory Inaction. Despite previous FCA reviews (2014 and 2025), Which? argues that no meaningful improvements have been made. The FCA is seen as failing to enforce its own rules under the Consumer Duty.
Which? gathered evidence from thousands of policyholders, Ombudsman Service decisions, and legal analysis. Their research suggests widespread confusion over policy cover and includes some distressing consumer case studies. It’s their view that the home and travel insurance markets are “broken” and consumers can’t afford to wait for positive action any longer.
Which? argues that these persistent problems amount to a failure by the FCA to protect consumers as required by law. They are urging the FCA to act decisively. They want a reform to claims-handling standards and improvements to accountability across the industry.
A note on fraud risks
While the complaint focuses on poor customer outcomes, it’s worth recognising that some areas of the insurance market – especially travel – are also vulnerable to fraud. From our own enquiries, we know this sector is prone to document manipulation, and international claims often take longer to verify.
“This is a sector where fraud is a genuine concern,” says Jamie Lankey, Technical Services Director at RGI. “Travel insurance, in particular, is exposed to manipulation that isn’t always easy to spot. Without proper checks (which take time) insurers risk being taken advantage of.”
These risks don’t excuse poor service, but they do show the challenge insurers face in balancing robust fraud checks with a fast and fair claims process.
What the Which? FCA super-complaint means for insurers
This intervention is extremely important. Insurers who ignore it risk regulatory sanctions, public backlash, and long-term damage to their credibility.
This super-complaint will bring about consequences for insurance firms. These can be broken down into three main areas:
- Scrutiny. Straight away a high-profile incident such as this brings insurers under the microscope. How they sell policies, handle claims, and communicate exclusions will all be under close watch for the time being.
- Reputational risk. The complaint includes real-life cases of consumers being “gaslighted” or denied claims on technicalities. Stories like these don’t make for happy reading and can damage public trust.
- Operational change. The purpose of a complaint is to bring about change. Firms might need to overhaul several aspects of their service, like their claims handling processes, policy documentation clarity, sales practices and disclosures.
So, what needs to change?
Accountability is key here. Insurers should avoid outsourcing claims in ways that could impact their service quality. Clarity for the consumer is of paramount importance, too. Firms must review their policy language and clearly highlight coverage limits and explain exclusions in plain and simple terms.
In the wake of this super complaint, it’s crucial that insurers are seen to be proactively compliant. Self-audits, engagement with FCA guidance and collaboration with industry bodies for standardised best practice are all ways in which insurers can put ethics at the forefront of their practice.
Is this a turning point for home and travel insurers?
The FCA response to Which?’s Super-complaint will be a pivotal moment to the home and travel insurance sector. The industry will need to change and provide a more customer-centric approach.
Which? are hoping this super-complaint will act as a catalyst for fundamental changes in how insurers treat their customers. The FCA is midway through the 90-day period to respond formally, investigate the issues, and decide on actions. Possible outcomes could be:
- Investigations
- Policy changes
- Enforcement actions
- Recommendations for legislative reform
What insurers should do now
There are, however, lots of proactive measures insurers can take straight away:
- Conducting urgent internal audits.
- Benchmarking claims handling processes against consumer duty standards
- Redesign and clarify policy documents
- Strengthen support for vulnerable customers
- Communicate and engage with industry bodies
We’re awaiting the outcome of the super-complaint which should be published by the 22nd December 2025. It’s a potentially damning indictment of the home and travel insurance sectors in the UK, but it’s one that we must all ultimately view as a positive action.
Which? are acting with consumer interests at heart, something that is very close to us at RGI. If this super-complaint refocuses the customer as the most important part of the industry, then we can only agree that this will be a good thing for all.
This super-complaint is a watershed moment. The appropriate outcome must go beyond reviews and promises. It should reset the standards for how insurance works in the UK. Consumers deserve clarity, fairness, and dignity, especially when they’re relying on insurance during life’s most difficult moments.