Welcome to the UKGI weekly regulation update service for Aviva ABC brokers

Context

The FCA has published its 2025 GI Value Measures Data, including the usual spreadsheet format in addition to the interactive web page.  The FCA publishes this data each year “to improve market transparency and give firms, consumer groups and other stakeholders a common set of indicators across a range of general insurance products”.

Key points to note and next actions

The data includes firm-specific information on claims frequency, claims acceptance rates, average claims payouts and claims complaints as a proportion of claims for a wide range of retail GI products.

The 2025 data shows:

• Across both home and travel insurance, claims complaints as a percentage of claims registered are high compared with other retail insurance products – home insurance (7-13%) and travel insurance (5-6%), whereas most other products fall between (0-6%). 
• In home insurance, claims acceptance rates are relatively low – 62-71% for home compared with 83-86% for travel and 99% for motor.
• Average claims payout increased across home insurance products, especially buildings and contents, where it rose by 17%.
• Claims costs as a proportion of premiums remained stable at 48% for home insurance, combining buildings and contents (46% in 2024).
• Claims costs as a proportion of premium increased across all three travel products (annual European, annual Worldwide and single-trip stand-alone) from 2024 to 2025 (44-48% in 2025 vs 31-37% in 2024). Premiums increased by 12% for these products but the amount paid out in claims increased by 47%.
• The FCA continues to see significant variation in claims costs as a proportion of premium, ranging from 17% for wedding and party insurance to 68% for healthcare cash plan (All).
• For Motor insurance, the largest retail general insurance product, premiums fell in 2025 by 7% while the average number of policies in force rose by 4%.
• Gadget insurance saw a fall in the percentage of premiums paid in claims, from 42% to 36% – one of the largest drops across all products.
• Travel insurance policies in force for single-trip travel insurance, stand-alone single-trip policies rose by 15% to 3.1 million in 2025 – however, these figures should be used with caution.
• The FCA’s web page includes commentary on factors to consider when analysing the data, data quality, and what the data includes.

Context

The FCA has decided to ban Alec Finch and his son Roert Finch from UK financial services after the High Court found that they had engaged in fraud and misused client money.  In light of the High Court judgment, dated 27 September 2023, the FCA decided that Alec Finch and Robert Finch failed to act with honesty and integrity in their roles at AFL Insurance Brokers Limited (AFL). 

Key points to note and next actions

• The father and son misused client money to fund AFL’s business expenses. When they later wanted to sell AFL, the pair made the business appear more financially attractive by creating false financial records to mislead the buyer, as well as their own accountants and auditors.
• They concealed the misuse of client money and overstated the firm’s financial position, leaving AFL burdened with a significant client money deficit.
• Alec Finch and Robert Finch have referred the Decision Notices to the Upper Tribunal where each will present their case. Any findings in the Decision Notices are therefore provisional and reflect the FCA’s belief as to what occurred and how it considers their behaviour should be characterised.
• Both Alec Finch and Robert Finch provided verifiable evidence that the imposition of a financial penalty of any amount would cause them serious financial hardship, otherwise the FCA would have imposed a financial penalty of £121,200 and £169,800 respectively.

Context

The FCA has published a consumer warning about Anthony Jones (UK) Limited, an insurance broker, urging them to check their insurance policies.  The firm has ‘agreed’, with effect from 9 July 2026, to stop carrying out any regulated activity, which means it cannot provide any services to an insurer.

Key points to note and next actions

• The firm cannot provide any services to an insurer, including selling new insurance policies, offering renewals, or providing any advice to new or existing consumers.
• If customers purchased an insurance policy through the firm, the FCA is asking them to contact the underwriter or insurer directly to check whether the policy is valid and the cover remains in place.  This perhaps indicates some concerns about monies not being passed to insurers, or policies not being created.
• The Voluntary Requirement placed on the firm also include asset-freeze provisions.

Context

The FCA has published its Attestations data for the last three quarters of its 2025/26 financial year.  Links are now provided to the data for Q1, Q2, Q3 and Q4 2025/26.  An attestation is a firm’s formal statement that it will take, or has taken, an action the FCA requires.  The FCA uses attestations as a supervisory tool to ensure that regulated firms – and senior individuals within them – are clearly accountable for taking required actions, often without ongoing regulatory involvement.

Key points to note and next actions

• The most usual situations when the FCA asks for attestations include notifications, undertakings, self-certification and verification.
• In Q1 2025/26 there was one insurance attestation (from a dedicated supervision firm, i.e., a ‘relationship managed’ insurance firm) out of a total of eleven. This was the only dedicated supervision firm that was required to submit an attestation.
• In Q2 2025/26, there was again one insurance attestation from a ‘portfolio supervision’ firm, out of a total of eight.
• In Q3 2025/26, there were 17 insurance attestations (five from dedicated firms and twelve from portfolio firms) out of a total of 27. This period, October to December 2025, coincided with the FCA’s work on home and travel insurance claims and the reaction to the Which? Super-Complaint on the subject, where a number of firms had to attest over improving their systems and controls, treatment of storm claims, and monitoring cash settlements.
• In Q4 2025/26, there were four insurance attestations (from portfolio supervision firms) out of a total of ten.

Context

The Bank of England and PRA have announced that the insurer HDI Global has been fined £4.165m in connection with the submission of incorrect FSCS Liabilities and FSCS Fee Tariff data to the PRA. This occurred on multiple occasions between August 2021 and August 2024 and included errors in data provided to the PRA in purported remediation of previously incorrect submissions.  HDI Global SE is a branch of a global insurance company headquartered in Hanover, Germany. In the UK, the Firm is regulated by the PRA and FCA.

Key points to note and next actions

• Misreporting of FSCS Liabilities may hinder the PRA’s ability to identify material risks and may also result in a firm underpaying any applicable levy to the FSCS.
• The errors in HDI Global SE’s submissions arose and persisted because of its failure to apply due skill, care and diligence to ensure that the data was calculated correctly.
• Prior to the summer of 2023, HDI Global SE failed to check the PRA Rulebook or guidance as to what liabilities are covered by the FSCS and the methodology for the calculation of the components of the FSCS Fee Tariff Data.
• HDI Global SE also had no effective written processes that would ensure that such calculations were carried out to any reliable standard, and there was a lack of clear accountability, internal oversight and challenge, reflecting a failure in organising and controlling its affairs responsibly and effectively. These failures resulted in inaccurate data being provided to the PRA.
• HDI Global SE has now implemented a number of remediation initiatives and has submitted corrected historical data and paid additional levies required to date by the FSCS to remedy the errors in respect of FSCS Fee Tariff data.

Context

FOS has published its latest complaints data and data insights for Q1 2026/27, showing that FOS received 53,600 cases in the first quarter of 2026/27.  This is more than the previous quarter (January to March 2026), but significantly fewer than the 68,000 complaints received in the same period last year (April to June 2025), when many cases related to motor finance commission (MFC).  Case levels, however, remained stable in the first quarter.  FOS has also published half-yearly complaints data for the second half of its 2025/26 financial year (1^st July 2025 to 31^st March 2026), which shows the number of complaints against financial businesses for which there were both 30 new and 30 resolved complaints in the relevant period.

Key points to note and next actions

• Current accounts were the most complained about product, with fraud and scams accounting for half of the cases in this area. 
• Travel and motor insurance case volumes both increased in the first three months of this financial year.
• Car and motorcycle insurance complaints rose to 4,100, up from 2,800 in the same period in 2025, and up on the 4,000 from January to March 2026, with consumers raising concerns about claim values, policy cancellations and claim delays.  
• Travel insurance complaints also rose by 30% (300) year-on-year to 1,300 cases, following earlier travel disruption linked to the conflict in the Middle East. Declined claims remained the most common issue. In January to March 2026, people submitted 1,200 complaints about this product.
• More consumers are referring their cases directly to the free service, without going through professional representatives.

Context

The ICO has published its Annual Report 2025/26, in which it confirms that John Edwards, the Information Commissioner, resigned from his role on 19 June 2026.  The resignation is ahead of the transition from the Information Commissioner’s Office to the Information Commission.  Edwards voluntarily stepped back from his duties on 26 February 2026 to enable an independent workplace investigation which related to him.  On 10 June 2026, the ICO confirmed that the investigation concluded that there was a case to answer and made clear that his behaviour fell short of the conduct expected from a public official.

Key points to note and next actions

• The Report sets out the results of what the ICO expects to be the last full year of the ICO. One outcome of the Data (Use and Access) Act 2025 (DUAA) is that the regulator will cease to be a corporation sole and will become a statutory board.
• The Report sets out the ICO’s purpose, strategic enduring objectives, values and causes, and reports on the progress made in relation to its enduring strategic objectives.
• The performance overview reviews the ICO’s work across 2025/26., sets out the ICO’s key achievements, and examines of some of the ICO’s most impactful work.
• The accountability report includes declarations about corporate governance, remuneration and staffing, parliamentary accountability and audit reporting.
• The financial statementsset out the ICO’s financial position, including the statement of comprehensive net expenditure, statement of financial position, statement of cash flows, statement of changes in taxpayers’ equity, and explanatory notes.

Context

Following a Consultation about updating its unfair contract terms guidance, the CMA has published a Summary of the Consultation responses, and has updated its Guidance on Unfair Contact Terms and its ‘Writing a fair contract for customers’ guidance web page.

Key points to note and next actions

• The Consumer Rights Act 2015 sets out the law on the use of unfair contract terms in consumer contracts.
• Although the law on unfair contract terms has not changed since 2015, so businesses’ obligations remain unchanged, the CMA updated the guidance to make it easier for businesses to understand unfair contract terms law and help them to comply, and to reflect other relevant developments, including direct consumer enforcement powers for the CMA under the Digital Markets, Competition and Consumer (DMCC) Act 2024.
• The guidance has been updated throughout, and we recommend that firms re-familiarise themselves with it and with the separate guidance on writing a fair contract for consumers.

Context

The CII has announced that it is to introduce changes in and improvements to its rules so that more customers can benefit from the services of a Corporate Chartered firm.  The CII is moving from a restrictive ‘one size fits all’ approach to support a wider range of firms and business models while continuing to maintain and enhance professional standards.  The rules will continue to be synonymous with quality, built on robust entrance criteria and ongoing monitoring.

Key points to note and next actions

• In a recent webinar the CII explained the changes it is making in relation to how firms evidence their eligibility for chartership status.
• The CII is outlining the changes to documentary evidence that it is now going to be requesting from firms which, according to the CII, firms should already have in place as part of being compliant with FCA regulations and Consumer Duty.
• The CII paper includes the reasons it is making changes, what it has been doing, what it has learned, and what is changing and when.  The new “evidence” requirements have been introduced in July 2026.
• The CII has included a set of FAQs in relation to the Consultation that has driven these changes.
•  On page 3 of the document the CII lists the new “evidence” that it will be requesting.  On page 4 it has also detailed what comes next and that, later this year, the CII will confirm timelines for future changes and lists what firms will be asked to demonstrate at that time.