In September 2025, the consumer advocacy group Which? submitted a super-complaint to the Financial Conduct Authority (FCA) setting out its concerns in relation to the poor outcomes it considers consumers are experiencing in the retail home insurance and retail travel insurance markets (the Complaint). On the basis of its research and investigations, Which? believes that, in these markets: (i) a large number of insurance firms are not complying with the relevant consumer and insurance laws and FCA rules, including the Consumer Duty; and (ii) existing consumer and insurance law frameworks may not be effective or sufficiently clear.
In our latest briefing note, we set out an action plan for steps firms could consider taking in light of the Complaint, as well as further detail regarding the Complaint itself, including the possible next steps the FCA will be considering.