On 18 December 2025, the Financial Conduct Authority (FCA) published an important statement outlining how it will expand its work to improve standards in the home and travel insurance markets following a super-complaint submitted by consumer champion Which?. This development is highly relevant for appointed representatives (ARs) operating in or alongside these markets, as it signals potential shifts in regulatory focus, risk oversight and compliance expectations for firms and their representatives.
A super-complaint is a powerful mechanism in UK financial services that allows approved consumer bodies to flag market-wide issues to the FCA that may be harming consumers. Which? raised concerns about claims handling quality, sales processes, and consumer understanding of policy terms in the home and travel insurance sectors.
While the FCA’s own data shows that around 79% of consumers are satisfied with how their claims are handled, nearly three in ten customers feel they lack sufficient information to judge the quality of different insurance policies. This gap in consumer understanding and expectations has driven the FCA’s decision to expand its planned work.
What the FCA Is Planning
Over the next year, the FCA will:
- Enhance oversight of claims handling, including how firms manage customer service and supervise third parties involved in claims processing.
- Analyse how insurance products are sold, with a particular focus on whether sales processes promote clear consumer understanding of cover.
The regulator also emphasised that it will continue to act against firms where concerns arise. Since its earlier review of home and travel insurance markets in July, the FCA has already taken concrete steps, including opening enforcement cases, restricting a firm’s operations until issues are resolved, and launching independent reviews into firms’ systems and controls.
Why This Matters for Appointed Representatives
For ARs in the insurance and credit sectors, this expanded regulatory focus underscores several compliance priorities:
- Enhanced supervision expectations: Principal firms will likely place greater emphasis on monitoring how ARs handle customer interactions and claims-related communications.
- Clarity in disclosures: ARs must ensure that product information, especially around insurance cover, is communicated in a way that helps customers make informed choices, supporting Consumer Duty outcomes.
- Data and record-keeping: Accurate records demonstrating how customer understanding and service quality are managed may become increasingly important in regulatory oversight.
Practical Takeaways
Appointed representatives should use this announcement as a reminder to review and strengthen compliance practices. Focus areas include quality assurance around claims support, training on clear product explanations, and robust oversight by principal firms. As the FCA intensifies its work in response to the super-complaint, maintaining strong governance and transparent customer communications will help ARs stay aligned with evolving regulatory expectations.
