FCA Post-Implementation Review Finds GI Value Measures Improve Transparency but Reveals Reporting Ga

Key Takeaways

• The FCA has published its post-implementation review of the general insurance (GI) value measures rules.
• It found positive effects on transparency, competition, and fair value compliance, but also inconsistent reporting across firms.
• Compliance teams should expect a consultation on minor changes in the first half of 2027 and should use the interim period to improve data quality and reporting accuracy.

Deep Dive

The FCA has published its post-implementation review of the general insurance (GI) value measures rules. It found positive effects on transparency, competition, and fair value compliance, but also inconsistent reporting across firms. Compliance teams should expect a consultation on minor changes in the first half of 2027 and should use the interim period to improve data quality and reporting accuracy.

The core requirements remain unchanged. Firms must report GI value measures data, including claims frequencies, claims acceptance rates, average claim pay-outs, and claims complaints as a percentage of claims. They must also ensure products offer fair value to customers in the target market. Reporting responsibility is determined by SUP 16.27.7R, 16.27.8R, and 16.27.9R, read together. For a single contract with a single insurer, the SUP 16.27.8R firm reports. For a contract with multiple insurers, such as optional extras, the insurer underwriting the main part of the cover reports, and the extras are reported under the main product category. Bundled contracts are reported separately by each responsible firm, using the SUP 16 Annex 48R product categories, subject to the exception in SUP 16.27.9R(2). Legal expenses and vehicle breakdown products are exempt from reporting average claims pay-out, total claims pay-out cost, and the amount above which the top 2% of pay-outs fall. Firms could enter £0 for these metrics in the first submission.

Reporting is annual, submitted via RegData by 28 February for the previous calendar year. The rules took effect on 1 July 2021, and the first report covered 1 July to 31 December 2021. The FCA publishes some of the data and uses it in supervision, so inconsistencies carry both reputational and supervisory exposure. The next milestone is the consultation expected in the first half of 2027, with no new obligations until then.

Recommended actions:
- Review the methodology behind prior submissions, especially for multi-insurer contracts, bundles, and optional extras, where responsibility and product categorization errors are most likely.
- Confirm that data-sharing arrangements with other firms in the distribution chain are documented and working.
- Benchmark published peer data against internal figures to identify outliers that may signal reporting errors or genuine value concerns.
- Align value measures outputs with fair value assessments and governance records.
- Monitor the consultation and engage with trade bodies or directly with the FCA.

Overall impact is low to moderate. No immediate changes are required, but the FCA's focus on consistency suggests closer scrutiny of data quality. Firms with weak controls over reporting or product classification face the greatest risk of supervisory follow-up. Proposed changes may later require system, data, and process updates.

Source: Financial Conduct Authority