FCA Proposes Removing Two GI Value Measures Reporting Requirements Following Post-Implementation Rev

Key Takeaways

• The FCA's CP26/33 finds that general insurance (GI) value measures have improved transparency and customer outcomes, but that inconsistent reporting limits the data's usefulness.
• It proposes two minor burden-reducing changes now and signals broader rule changes in the first half of 2027.
• Responses are due by 9 October 2026, so compliance teams have a short window to comment and should begin planning for the wider reforms.

Deep Dive

The FCA's CP26/33 finds that general insurance (GI) value measures have improved transparency and customer outcomes, but that inconsistent reporting limits the data's usefulness. It proposes two minor burden-reducing changes now and signals broader rule changes in the first half of 2027. Responses are due by 9 October 2026, so compliance teams have a short window to comment and should begin planning for the wider reforms.

CP26/33 combines a post-implementation review of the GI value measures rules (introduced through PS20/9 and effective in 2021) with a consultation on two standalone changes. The FCA proposes to remove the requirement to report (1) the amount (in GBP) above which the top 2% of claim pay-outs fall for each product, and (2) the five largest distribution arrangements. The FCA states that these changes reduce reporting burden without materially reducing the data's usefulness. The draft Handbook text is in Appendix 1. The consultation paper text we have is truncated after Chapter 4, so the detailed findings in Chapters 5-7 and the specific consultation questions should be reviewed in the full document.

The FCA concludes that the rules have improved transparency, encouraged better customer outcomes and supported fair value assessments. About 90% of the 48 surveyed firms reported a positive or somewhat positive impact. Firms use the data mainly for internal governance, peer benchmarking and fair value inputs under PROD 4 and the Consumer Duty. However, the FCA identifies reporting inconsistency, driven by differing interpretations of the rules and product structures. Stakeholders also raised ambiguous rules, a risk of misreporting, and the lack of data splits by consumer-facing brand. The FCA is also considering publishing more data, and publishing it more often. It is exploring how AI tools that surface the public data may affect consumer understanding. The review also draws on the 2025 Which? super-complaint on home and travel insurance claims, and on declining claims experience indicators (such as Financial Lives survey results).

Comments on the two proposals are due by 9 October 2026, by the FCA web form, by email to cp26-33@fca.org.uk, or by post. The FCA expects to consult on wider changes to the value measures rules in the first half of 2027. An industry working group of trade bodies and 16 firms is already helping shape those changes. Note that the FCA has already decommissioned the PROD 4.5 value measures rules earlier in 2026, because they duplicated the GI Pricing Practices rules.

Recommended actions:
- Assess the operational effect of removing the two data fields, including any reporting system, data pipeline and governance changes.
- Submit a response by 9 October 2026, and consider participating in trade body or working group discussions.
- Review current value measures submissions for interpretation inconsistencies, brand-level granularity and misreporting risk, as the FCA is signaling more scrutiny.
- Keep reporting the affected fields until the final rules take effect.
- Prepare for potential changes to the scope, granularity and publication frequency of the data.
- Strengthen claims handling management information, oversight of third parties and customer communications, which are focus areas for the FCA.

The immediate impact is low and mainly reduces burden. The larger risk is strategic, because the 2027 consultation could bring tighter definitions, more granular reporting and more frequent publication. This would increase reputational and supervisory exposure for firms with outlier claims metrics. Claims outcomes remain a key supervisory priority under the Consumer Duty, so data quality and consistency failures could attract regulatory attention.

Source: Financial Conduct Authority