The Super-Complaint, the FCA response and an opportunity to elevate the claims proposition
The Which? super-complaint and the Financial Conduct Authority (FCA)'s subsequent response have become an important catalyst for change across the insurance market. Together, they have accelerated industry-wide discussions around claims quality, consumer understanding, supply-chain oversight and the practical application of Consumer Duty.
Throughout 2026, these themes have moved further up the agenda for insurers, brokers and claims service providers, reinforcing the importance of transparency, accountability and demonstrable customer outcomes across the entire claims journey. The result is a stronger focus on how firms deliver fair value to customers, particularly at the point of claim, when the true value of insurance is tested.
The Which? super-complaint: driving reform
Filed in September 2025 under the statutory super-complaint mechanism, Which?'s submission targeted standards in the home and travel insurance markets, including claims handling and point-of-sale processes.
The complaint raised concerns about poor claims handling, opaque sales practices, product complexity and potential breaches of Consumer Duty principles.
The FCA's response: expanded scrutiny, not inaction
The FCA rejected suggestions that it had failed to act but acknowledged areas where further work was required. The regulator highlighted concerns relating to policy complexity, customer understanding, sales practices and oversight of outsourced claims handlers.
In 2026, the FCA advanced its work on point-of-sale practices, customer understanding and claims service quality in the home and travel insurance markets. It focused particularly on firms’ oversight of outsourced claims handling and delegated authority arrangements, while seeking to improve consumers’ understanding of policy coverage and product value.
While most consumers remain satisfied with claims handling, regulator research continues to show that many consumers struggle to assess the quality and suitability of insurance products before purchase.
The FCA has continued to demonstrate its willingness to intervene where consumer outcomes fall short of expectations. Enforcement investigations, independent reviews and targeted supervisory action have reinforced the message that firms must be able to evidence good customer outcomes, effective governance and robust oversight arrangements.
Claims handling in scope
As part of insurers' supply chains, claims management professional service firms such as Crawford are directly in scope where outsourced claims handling is concerned. The FCA has made clear that delegated authority arrangements do not dilute insurers' regulatory responsibilities.
This environment elevates the role of claims. Claims handling has become firmly established as a frontline indicator of fair value and customer outcomes.
An opportunity to differentiate
The overarching objective from all sides is to deliver fair value, transparency and better outcomes for consumers.
For Crawford, the regulator's sharpened focus on consumer outcomes is welcome and aligns closely with the company's commitment to restoring lives, businesses and communities.
Crawford recognises that insurers require greater assurance that supply-chain partners are delivering consistent, quality service fully aligned with Consumer Duty expectations.
Crawford works to continue expanding governance frameworks, strengthening oversight, enhancing outcome-focused reporting and embedding customer-centric decision making, particularly where vulnerability has been identified.
Crawford also continues to strengthen its commitment to customer excellence through collaboration with the Institute of Customer Service and ongoing investment in technology and digital claims experience, including intelligent document processing and AI-enabled triage.
The work of restoring lives requires engaging with people during some of their most difficult and vulnerable moments. Authenticity, emotional intelligence and empathy remain central to effective claims handling.
From scrutiny to leadership
The Which? super-complaint and the FCA response together have acted as a catalyst for change across the insurance landscape. They have strengthened the focus on claims quality, transparency and accountability, while reinforcing the principle that outsourcing does not lessen responsibility.
By investing in governance, strengthening data transparency, amplifying customer-centric practices and collaborating closely with clients, brokers and regulators, Crawford is positioning itself at the forefront of a more accountable, outcome-focused claims environment.
As regulatory expectations continue to evolve, firms that can clearly evidence robust governance, effective oversight and consistently positive customer outcomes will be best positioned to build trust and create competitive advantage.
