COVID-19 and vacation insurance policy: The FCA updates its expectations of typical insurance policies firms | Bryan Cave Leighton Paisner

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The FCA, on 19 July 2021, up-to-date its webpage setting out its expectations of standard insurance policies corporations in the mild of COVID-19 to clarify its expectations about vacation insurance coverage. Despite the fact that the FCA experienced earlier published information of its expectations of companies in this discipline, the most current update offers further colour on the techniques that the FCA expects basic insurance plan corporations to be having (or to have taken) and the methods that it does not regard as proper.

FCA’s up to date anticipations in relation to travel insurance plan

Standard insurance coverage companies should really be informed of the pursuing updated anticipations that have now been set out by the FCA:

1. Good, very clear and not deceptive purchaser communications during the marketing and advertising and sales processes.

The FCA has emphasised that:

  • Firms ought to not use terminology that customers might not understand. In particular, the FCA notes that some firms have been advertising and marketing and promoting items that have “coronavirus protect” or “increased COVID-19 include”. The FCA is worried about this, as these phrases do not have a commonly comprehended meaning and can replicate quite distinct sorts of go over based on the company.
  • Corporations should deliver buyers and potential consumers with crystal clear facts and assure they have a crystal clear knowledge of the extent that vacation merchandise will guard them against COVID-19-relevant threats. Corporations offering travel coverage will have to ensure that prospects are provided appropriate data about a policy so that they can make an knowledgeable choice. This will contain delivering apparent facts about the coverage, like the key gains, restrictions, conditions and exclusions which include those people relating to COVID-19, regardless of the “sophistication” of the client and whether or not they have beforehand purchased a vacation plan from the firm. Where exclusions are in place, they should be adequately distinct so that buyers fully grasp the effect and scenarios in which the coverage will not spend out.

2. Demands and wants.

The FCA has reiterated its emphasis that corporations ought to only offer customers journey insurance policies that satisfies their calls for and requirements. 

3. Merchandise governance: 

In relation to product governance necessities, the FCA has clarified that:

  • It considers that changes to an existing travel insurance policies product or service to exclude the insurer’s legal responsibility for threats relating to coronavirus are very likely to volume to a sizeable adaptation of that products, for that reason triggering a new product approval approach.
  • Additional to its steering on “Product worth and coronavirus”, it now expects products manufacturers to have reviewed their journey insurance coverage items and to have recognized if coronavirus has affected their intended price.
  • As part of ongoing solution monitoring, it expects corporations to look at available data on vacation insurance coverage products – these as the variety of, and cause for, claims currently being declined. It notes that this facts could show that the solution has distributed outdoors of the recognized focus on sector or that the customer practical experience does not match what the company experienced predicted.


Several of the FCA’s updated anticipations in relation to journey insurance plan will not arrive as a shock to typical insurance plan companies and lots of firms will, no doubt, presently be acting in accordance with these. Even so, in situations where customer safety is at the leading of the FCA’s agenda, and specially the safety of customers who are in a susceptible situation mainly because of the COVID-19 pandemic, they do deliver some perception into in which the FCA’s enforcement aim is possible to be in regard of journey insurance policy. Firms would be perfectly encouraged, therefore, to re-assess their product or service governance, internet marketing and income procedures in relation to journey coverage to make sure that they do not fall limited of these anticipations.

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