[co-author: James Wilkinson]

Some consumers with pre-existing medical conditions (“PEMCs”) have problems navigating the travel insurance market and finding affordable cover given their medical conditions. Some are declined cover, only offered cover that excludes their PEMC or are offered what they consider to be unaffordable premiums. To address this problem, the FCA is introducing new signposting rules and guidance designed to help customers better navigate the travel insurance market and achieve better outcomes.

Background

In July 2019, the FCA consulted on new requirements for firms to signpost certain consumers with PEMCs to a directory of travel insurance firms that are able and willing to cover consumers with more serious PEMCs. The FCA received 37 responses to the consultation from mainstream and specialist insurance firms, FCA trade bodies, medical screening companies, charities, consumer organisations and price comparison websites. Policy Statement PS20/3 (published yesterday) summarises the feedback received to this consultation, the FCA’s response and sets out the final rules and guidance the FCA is making as a result.

Overview

The FCA has made changes to the Handbook, introducing new requirements to help consumers with more serious PEMCs better navigate the travel insurance market. Firms that sell travel insurance will have to signpost consumers to a directory of specialist firms that provide this type of insurance.

Who is affected?

• all firms that offer retail travel insurance, including insurers, Lloyd’s managing agents, intermediaries and appointed representatives;
• banks that offer packaged bank accounts which include travel insurance;
• insurance industry trade associations;
• charities, particularly medical charities;
• consumer organisations; and
• consumers, primarily those with PEMCs.

What is changing?

• firms will be required to signpost certain consumers with PEMCs to a directory of specialist providers;
• guidance will be introduced for firms selling travel insurance policies that exclude PEMCs instructing those firms to tell consumers whether, and how, PEMC exclusions can be removed;
• additional guidance will be introduced to remind firms to assess the risk associated with medical conditions and calculate medical condition premiums using reliable information that is relevant to the assessment of that risk;
• Detailed guidance on the changes to the FCA Handbook wording and example scenarios can be found in PS20/3.

Next Steps

• Firms affected by the changes are required to include details of the directory on their websites within 30 days of becoming aware of the directory going live. All other new requirements outlined in PS20/3 must be implemented by 5 November 2020.
• The Money and Pensions Service is to provide further information about the application process for firms wishing to be included in the directory by the end of February 2020. The directory itself should be completed by Summer 2020.