The home and travel insurance claims ‘super-complaint’ - What you need to know and what you need to do about it

The Which? super complaint into home and travel insurance is a significant development for insurers, MGSs, TPAs, and the wider property claims supply chain.

It is not simply another consumer campaign or isolated regulatory issue. It reflects a wider concern that claims handling, customer understanding, and third-party oversight may be contributing to poor outcomes across parts of the insurance market.

For property claims, the implications are especially important. Claims are delivered through a complex ecosystem of insurers, handlers, loss adjusters, surveyors, contractors, validation specialists, drying companies, contents suppliers, and alternative accommodation providers. The insurer may bear regulatory responsibility, but the customer experiences the overall performance of the entire value chain.

The FCA has now moved beyond its initial response to the super-complaint and into follow-through supervisory work. Its focus includes claims handling, customer service, consumer understanding, and the oversight of third parties involved in claims delivery.

For firms in the property claims market, the message is clear: it will no longer be enough to show that processes were followed or SLAs achieved. Firms need to evidence fair, timely, and understandable outcomes across the full claims journey.

What is a super-complaint?

A super-complaint is a formal complaint made by an approved consumer body, such as Which? or Citizens Advice, to a regulator about a problem that appears to be causing significant harm to consumers across a market.

In simple terms, it says: this is not just a small number of individual complaints; there may be something in the way the market operates that is systematically harming customers.

That is why super-complaints matter. They are made by recognised independent consumer bodies and are therefore considered credible, substantive, and potentially market-wide. They are not about a single poor outcome or a single badly handled claim. They are about whether features of a market, or combinations of them, may be damaging to consumer interests.

Regulators are required to respond within a defined timeframe and may then publish findings, demand changes, increase supervision, require firms to improve practices or, where appropriate, take enforcement action.

Previous super-complaints show why the insurance claims super-complaint should not be dismissed simply because the FCA has completed its initial response. Super-complaints often act as catalysts rather than one-off events. 

The Payment Protection, Dual Pricing, and Gender Discrimination in pricing super-complaints all began with concerns about consumer harm that appeared systemic rather than isolated. They created almost instant furore and allegations of industry malpractice, but importantly, over time, they led to market studies, new rules, redress exercises, changes in behaviour, and sustained regulatory scrutiny. The lesson for insurers and property claims suppliers is clear: the immediate FCA response will only be the start of a longer period of supervisory attention and market change.

What does the recent insurance super-complaint address?

The Which? super-complaint focuses on home and travel insurance and raises concerns about whether customers receive fair outcomes when they need to make a claim.

At its heart, the complaint is about whether insurance is doing what customers reasonably expect at the point of need. Customers buy insurance for protection, reassurance, and financial resilience. The claim is where that promise is tested.

Which? submitted its super-complaint to the FCA in September 2025, arguing that consumers were experiencing poor outcomes in home and travel claims. The FCA responded in December 2025, confirming that it would expand its work in these markets, including customer service, claims delivery, and the way firms oversee third parties involved in claims handling.

That final point is particularly important for property claims. Property claims are rarely delivered by a single firm acting in isolation. The customer journey may involve FNOL teams, claims handlers, loss adjusters, surveyors, repair networks, drying specialists, contents providers, alternative accommodation partners, data providers and cash settlement teams.

The insurer may own the regulatory responsibility, but the customer experiences the combined effect of the entire claims ecosystem.

What immediate issues should concern property claims stakeholders?

For property claims, the risks are clear. A claim may be technically covered but still result in a poor outcome if the customer is passed between parties, receives inconsistent messages, faces avoidable delays, or is offered a cash settlement they do not fully understand.

Equally, a claim may be declined correctly but still handled poorly if the explanation is unclear, the evidence is not properly shared, or the customer feels the decision has been reached through process rather than judgment.

The super-complaint, therefore, shifts the debate from isolated service failures to systemic market confidence. It asks whether poor claims handling, unclear communication, weak customer understanding, and insufficient oversight are features of the market rather than exceptions within it.

For those operating in the property claims value chain, that is an important distinction. The question is no longer simply, “Did we follow the process?” It is, “Did the customer receive a fair, timely, and understandable outcome, and can we evidence that?”

How does this link to Consumer Duty?

The super-complaint links directly to Consumer Duty.

Consumer Duty requires firms to act to deliver good outcomes for retail customers. In claims, that cannot be demonstrated simply by showing that a diary date was met, a process was followed, or a supplier SLA was technically achieved.

The more important question is whether the claim outcome was fair, whether the customer understood what was happening, whether avoidable delay was prevented, and whether the firm can evidence effective oversight across all parties involved.

For insurers and MGAs, this has significant implications. The FCA’s response specifically refers to a review of the oversight of third parties that handle claims. That brings delegated authority models, outsourced claims functions, TPA relationships, repair networks, and supplier remuneration structures into sharper focus.

This does not mean supply chains are the problem. In property claims, specialist suppliers are essential to delivering good outcomes. The issue is whether the supply chain is designed, governed, and measured around customer outcomes as well as cost control.

A low-cost supplier model that leads to delays, repeated contact, poor communication, or unsuitable settlement decisions may appear efficient internally while creating regulatory and reputational risk externally.

What areas of claims handling are likely to come under scrutiny?

Several areas are likely to attract particular attention.

The first is third-party oversight. Insurers and MGAs will need to show that suppliers are properly selected, managed, monitored, and challenged. Traditional scorecards based on cost, lifecycle, and complaint volumes will not be enough on their own.

The second is communication. Customers need clear, consistent, and timely explanations, particularly where claims are complex, declined, partially accepted, or subject to technical investigation.

The third is cash settlement. Cash settlements can be entirely appropriate and may suit many customers. But they become problematic if the customer does not understand the basis of the offer, if the amount is not realistic for reinstatement, if vulnerability is not considered, or if cash is used mainly to close the claim quickly rather than deliver a fair outcome.

The fourth is vulnerable customer handling. Property claims often arise at moments of distress, disruption, or financial pressure. Firms need to consistently identify vulnerabilities and ensure that support follows the customer throughout the entire claims journey.



The fifth is complex property claims, including storm, flood, escape of water, and subsidence. These claims often involve technical decisions, multiple suppliers, and emotionally charged circumstances. The outcome depends not only on the coverage decision, but on how the process is explained and coordinated.

Where is the FCA now with this process?

The FCA is past the initial response stage and is now in the follow-through and supervisory phase.

The super-complaint has not led to any dramatic intervention, such as an immediate full-market study or a new rulebook. Instead, it has sharpened and widened the FCA’s existing work on home and travel insurance.

For property claims, the most important live point is the FCA’s focus on outsourced and third-party claims processes. That brings TPAs, loss adjusters, repair networks, surveyors, validation providers, drying contractors, contents suppliers, and alternative accommodation providers directly into the spotlight.

The direction of travel is clear. The FCA is moving from “we have responded” to “we are now testing whether firms are improving outcomes.”

What should firms do now?

Insurers, MGAs, and suppliers should treat the super-complaint as both a regulatory warning and a strategic opportunity.

The practical response should include reviewing supplier governance, strengthening MI, testing customer outcomes, improving communication, scrutinising cash settlement practices, and ensuring that vulnerable customers are consistently supported throughout the claims journey.

For suppliers, the opportunity is to move beyond being seen as operational providers and to position themselves as outcome partners. That means being able to evidence contribution to fair customer outcomes, not simply delivery against task-based SLAs.

The importance of the super-complaint lies in the fact that it crystallises a wider shift already underway. Claims are no longer a back-office fulfilment function. They are the point at which product value, customer trust, operational resilience, and regulatory compliance converge.

For the property claims value chain, the firms that respond best will be those that can balance indemnity control with genuine customer care — and evidence that balance clearly.

Summary

The Which? super-complaint is important because it brings together several issues that were already moving up the regulatory agenda: claims handling, Consumer Duty, customer understanding, vulnerable customers, cash settlements, and third-party oversight. For property claims, the message is particularly clear. 

The customer outcome is not created by the insurer alone, but by the collective performance of the full claims value chain. Insurers, MGAs, TPAs, and suppliers, therefore, need to move beyond process compliance and demonstrate that their claims models deliver fair, timely, and understandable outcomes in practice. 

Those that can provide clear evidence of this will be better placed to meet regulatory expectations, strengthen customer trust, and differentiate themselves in an increasingly outcome-focused market.