Insurance Super-Complaint 2026: What It Means | IDS

Insurance industry & disputed claims

‘Broken’ Insurance Industry: What the Super-Complaint Means for Your Claim in 2026

A year after Which? challenged the home and travel insurance markets, regulatory scrutiny continues. But for someone facing a rejected claim, an inadequate settlement or months of delays, the most important question remains: is the insurer’s position actually justified?

Written by Mr Gary Smith Legal Director and Insurance Expert Updated
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Editorial illustration of an insurance specialist reviewing a Which? super-complaint news report attributed to BBC News, alongside home and travel claim documents
1 The Which? super-complaint
2 What has changed in 2026
3 What it means for your claim

An investigation into the insurance industry does not, by itself, repair your home.

It does not explain why your claim has been refused. It does not establish whether the settlement you have been offered is enough. And it does not resolve the disagreement between your contractor and the insurer’s loss adjuster.

That distinction matters.

On 23 September 2025, Which? launched a super-complaint against the home and travel insurance markets, alleging serious problems with claims handling, sales practices and the enforcement of consumer protections. Its concerns went beyond isolated mistakes: Which? argued that these markets were failing too many of the people relying on them.[1]

Since then, the Financial Conduct Authority has announced additional action, and the issue has reached a parliamentary inquiry.[2][4]

For policyholders, that is important background.

But your claim still needs its own assessment. The existence of an industry-wide problem does not prove your insurer is wrong—and an insurer’s rejection letter does not prove it is right.

What has happened since the BBC’s original report?

The BBC article reported the launch of the super-complaint. The position has moved on.[13][2]

On 18 December 2025, the FCA published its response. It said that, following its earlier home and travel claims review, it had opened two enforcement cases, commissioned three independent reviews, restricted one firm’s ability to grow its business and required three senior managers to address problems and consider whether redress was due. These were actions announced at that time, not findings that every insurer had broken the rules.[2]

The regulator’s full response also said it had asked 13 of the 15 home insurers in its sample to review their handling of storm claims and/or cash settlements to establish whether customers had suffered harm.[3]

The scrutiny has continued into 2026.

At a House of Lords hearing on 2 September 2026, FCA representatives described eight workstreams covering claims, customer service, sales processes and contractual terms. They also said the regulator planned to contact around 300 firms later in the year to better understand what was being outsourced and to whom.[4]

These developments should not be confused with a blanket decision to reopen every rejected insurance claim.

They do, however, reinforce why a substantial rejection or settlement reduction deserves more than unquestioning acceptance.

The latest figures still raise questions

The FCA’s latest annual general insurance value measures, covering 2025 and published in July 2026, reported the following claims acceptance rates across the relevant product categories:[5]

FCA value measures · 2025 data · These are claims acceptance rates, not Ombudsman uphold rates.
Insurance categoryReported claims acceptance rate
Home insurance62–71%
Travel insurance83–86%
Motor insurance99%

The FCA also reported that claims-related complaints, measured against claims registered, were comparatively high in home and travel insurance.[5]

There is an important qualification: the FCA warns that inconsistencies in how firms report home-insurance claims acceptance data mean these figures should be used cautiously. They are not a reliable basis for declaring that a particular proportion of valid claims has been wrongly rejected. Nor are they Financial Ombudsman complaint uphold rates.[5]

The figures provide context—not a verdict on your claim.

And a further point in the FCA’s September 2026 work deserves particular attention.

A claim recorded as “accepted” may still leave you disputing the payout

In its September 2026 review of insurance value measures, the FCA explained that a claim involving several separate elements can be recorded as accepted when the insurer pays one of them. It also acknowledged that claims can be treated as accepted even when the payout is lower than the customer believes they are due.[6]

This is a limitation of the statistics, not proof that those settlements are wrong.

But it explains why the difference between “claim accepted” and “claim properly resolved” matters.

Consider an illustrative example.

Your home suffers substantial water damage. Your contractor estimates the necessary repairs at £75,000. The insurer accepts that an insured event occurred but offers £45,000.

There is a £30,000 disagreement.

The higher quotation does not automatically establish what the insurer must pay. Equally, the fact that the insurer has accepted the claim does not resolve whether its repair scope, pricing and deductions are correct.

The dispute has moved from whether the insurer will pay to whether it is paying the right amount.

At Insurance Dispute Service, we review underpaid claims as well as outright rejections. A payment offer is not, by itself, a reason to assume there is nothing left to examine.[12]

Rejected claim—or an offer that leaves a serious shortfall?

Send us the insurer’s decision, your policy and the evidence you already have. Start by finding out what is actually in dispute.

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Optional service. Any further paid work would be explained and agreed separately.

A cash settlement can leave the hardest decisions with you

A cash offer can sound like progress.

After weeks of calls, inspections and uncertainty, there is finally a figure on the table.

But before treating that figure as the solution, consider what accepting it would require you to do.

Can you obtain the proposed repairs for that amount? Does the offer reflect the work actually needed? Are significant items missing from the scope? What happens if further damage is discovered?

The FCA’s 2025 claims-handling review identified weaknesses in some firms’ oversight of cash settlements. It raised concerns about settlements based on discounted contractor rates unavailable to the customer, inadequate consideration of vulnerability and customers choosing cash because they believed insurer-arranged repairs would take too long.[7]

That does not make cash settlements inherently unfair.

It makes the basis of the offer important.

A useful assessment should compare the settlement with the policy, the damage evidence and the proposed repairs—not simply ask whether the amount sounds reasonable.

Before exchanging an unresolved claim for a fixed sum, understand which problems that sum will actually solve.

Outsourcing does not remove the insurer’s responsibility

A policyholder may find themselves dealing with several organisations: the insurer, a claims administrator, a loss adjuster, a surveyor and a repair contractor.

From your perspective, the difficulty may be straightforward: you have reported a loss and need a decision or suitable repairs.

Yet the explanations can become circular. One party is awaiting instructions. Another needs a report. Someone else is waiting for authorisation.

During the September 2026 parliamentary hearing, the FCA reiterated that an insurer remains responsible for claims outcomes when it delegates the work. Outsourcing can be beneficial, but responsibility stays with the company.[4]

For a disputed claim, our starting questions would therefore be practical:

Who made the disputed decision? What information did they use? What remains outstanding? And who has responsibility for resolving it?

Being passed between different organisations is not the same as having your claim properly assessed.

“It is in the policy” does not answer every question

Policy wording matters. So does how the cover was explained and how the insurer has applied it to the facts.

An example raised during the 2 September 2026 parliamentary evidence session illustrates the potential disconnect.

The Financial Ombudsman described a travel policy whose advertising showed off-piste skiing even though that activity was excluded. The Ombudsman said it had given the firm feedback about the issue.[8]

That example does not establish that every misunderstood exclusion is invalid.

It does show why an assessment may need to look beyond a single paragraph in the rejection letter.

For a disputed exclusion, we would want to establish the exact wording relied upon, the circumstances of the loss and why the insurer says the exclusion applies. Where relevant, we would also examine the sales material and information provided when the policy was arranged.

The question is not simply:

“Does the policy contain an exclusion?”

It is:

“Does that exclusion justify this decision, in these circumstances?”

Poor service and an incorrect claim decision are different problems

A claim can involve unacceptable service without the underlying loss being covered. Conversely, an insurer can communicate politely and promptly while reaching a decision that deserves challenge.

Those issues should not be muddled together.

FCA claims-handling rules require insurers to deal with claims fairly and promptly, give appropriate assistance and progress information, avoid unreasonable rejection and pay promptly once settlement terms have been agreed. They do not require insurers to pay every loss reported to them.[9]

The regulator’s December 2025 response also reported that 79% of consumers making insurance claims were satisfied with their handling, across insurance more broadly. It would therefore be wrong to portray every insurer or every claims process as failing.[2]

For your claim, the useful distinction is between:

the service you received; the decision on cover; and the amount offered.

One, two or all three may need attention. A review should identify which—not simply produce a longer complaint about everything that has happened.

The super-complaint is not a substitute for challenging your own decision

Which?’s action concerns the operation of the home and travel insurance markets. It is not an individual ruling on your rejection letter, your repair estimate or your policy exclusion.[1]

That is why sending an insurer a news article and saying “this proves you are wrong” is not enough.

The more useful questions are specific.

Has the insurer overlooked evidence? Has it misunderstood what caused the damage? Is the repair proposal adequate? Is the settlement based on a defensible valuation? Has it explained a deduction rather than merely applied one?

Those are the questions we would want answered before advising on a substantial dispute.

An industry investigation can identify patterns. A claim review must establish whether those patterns—or other errors—appear in your case.

Do not let the wider investigation distract you from deadlines

Waiting for regulatory reform is not a reason to leave your own dispute unattended.

For most insurance complaints, the insurer normally has eight weeks to respond. Where the Financial Ombudsman has jurisdiction, referral is usually required within six months of the insurer’s final response, subject to limited exceptions.[10]

You can complain directly to the insurer and, where eligible, use the Financial Ombudsman free of charge without appointing a representative. Specialist assistance is optional.[11]

The practical point is to understand your options and protect the relevant deadlines while the evidence is assessed.

Do not assume that the super-complaint, continuing correspondence or an initial review has extended the time available to you.

Before accepting the decision, understand what is actually in dispute

If your claim has been rejected, significantly reduced or left unresolved, start with the documents that explain the disagreement.

The most useful starting material is usually the insurer’s decision or settlement letter, the policy wording and schedule, the relevant reports and evidence of the loss. For a delayed claim, a clear chronology can help identify where progress stopped.

At Insurance Dispute Service, our free initial review is intended to identify the central dispute and explain the realistic routes available.[12]

The purpose is not to promise that every decision can be overturned.

It is to establish whether there is a substantive issue worth pursuing—and what would need to be examined before taking the matter further.

For a substantial property loss, that might mean distinguishing a disagreement about cover from a disagreement about causation or repair costs. For another claim, it might mean identifying why the insurer’s stated reason does not address the evidence you have supplied.

You do not need another general explanation of why insurance can be frustrating. You need to understand whether your particular insurer’s position stands up.

Has your insurance claim been rejected, underpaid or left unresolved?

The super-complaint has put the treatment of policyholders under scrutiny.

Your claim deserves scrutiny too.

Send Insurance Dispute Service the insurer’s latest decision, your policy and the supporting documents you already have. Tell us what happened, what remains disputed and how much is at stake.

Start your free initial claim review.

Your insurer has given you an answer.

Before accepting it, find out whether that answer is supported by the policy and the evidence.

Important information

This article provides general information, not legal advice. The Which? super-complaint concerns home and travel insurance and does not establish an automatic entitlement to compensation. IDS is an optional service, separate from Which?, the BBC, the FCA and the Financial Ombudsman. The initial review is free; any further paid service would be explained and agreed separately. Outcomes depend on the individual claim, policy, evidence and applicable deadlines.

Frequently asked questions

Does the Which? super-complaint mean my insurer must pay?

No. It concerns the home and travel insurance markets, not a ruling on every individual claim. Your policy, the circumstances of the loss and the insurer’s reasons still need to be examined.

Can I still have a dispute if my claim was accepted?

Yes. You may still disagree about the repair scope, the amount offered, deductions or parts of the claim that were not paid. Acceptance and correct valuation are separate questions.

Should I wait for the regulatory investigation to finish?

Do not assume that waiting protects your position. Complaint and legal deadlines can still apply. Check the dates in your insurer’s correspondence while considering your next steps.

Do I have to appoint someone to complain for me?

No. You can complain directly to the insurer and, where eligible, use the Financial Ombudsman free of charge. IDS is an optional service; any further paid work would be explained and agreed separately.

What should I send for a free initial claim review?

Start with the insurer’s latest decision or settlement letter, the policy wording and schedule, relevant reports and evidence of the loss. Explain what remains disputed and how much is at stake.

Sources and further reading

Original BBC report: 23 September 2025. The regulatory developments and figures below were checked for this September 2026 update. Links identify the source behind the corresponding reference in the article.

  1. Which? — launch of the insurance super-complaint, 23 September 2025
  2. FCA — response and enforcement action announced on 18 December 2025
  3. FCA — full response to Which?, including storm and cash-settlement reviews (PDF)
  4. House of Lords — FCA oral evidence, 2 September 2026
  5. FCA — general insurance value measures data 2025, published July 2026
  6. FCA — September 2026 value measures review, CP26/33, paragraphs 6.5 and 6.12 (PDF)
  7. FCA — home and travel claims-handling review, including cash settlements
  8. House of Lords — Financial Ombudsman oral evidence, 2 September 2026
  9. FCA Handbook — ICOBS 8.1, claims-handling requirements
  10. Financial Ombudsman Service — complaint time limits
  11. FCA — how to complain and the free Financial Ombudsman route
  12. Insurance Dispute Service — free initial claim review
  13. BBC News — original report by Kevin Peachey, 23 September 2025

The hero is an editorial illustration, not a reproduction of a BBC page. References to Which? and BBC News identify the complaint and its reporting; they do not imply endorsement of Insurance Dispute Service.

Free initial insurance claim review

Your insurer has given you an answer. Does it stand up?

Send us the decision, your policy and the evidence you already have. Tell us what remains disputed and how much is at stake.

Start by understanding your claim—not simply accepting the rejection or the offer.

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Optional service. Initial review free; further paid work agreed separately.