The Financial Conduct Authority has been simplifying parts of the insurance rulebook.

By 27 July 2026, the first summer package of targeted amendments had largely come into force. Most of the relevant insurance changes took effect on 26 June, with a remaining group commencing on 27 July.

The package removed or rationalised several outdated, duplicated or low-value requirements applying to insurers and intermediaries. It included changes affecting product-governance and reporting provisions, alongside other targeted Handbook clarifications. The FCA’s stated aim was to reduce unnecessary regulatory complexity while maintaining appropriate customer protection.

Further insurance simplification proposals were also published at the end of June.

Those proposals included removing some disclosure requirements considered duplicative, allowing greater flexibility in digital communication and drawing a clearer distinction between sales involving a personal recommendation and those that do not. But as of 27 July, those further proposals remained under consultation and were not final rules.

For care providers, the distinction is important.

The summer reforms concern how regulated insurance firms operate and communicate. They do not rewrite the individual contract held by a care organisation. They do not automatically alter a policy’s exclusions, conditions, excesses or limits. And they do not remove the legal responsibilities that can apply to a business purchasing commercial insurance.

The practical message is therefore more measured than the headline “insurance rules changed” may suggest:

The regulatory framework may be becoming simpler for insurance firms. The provider’s risk, disclosure responsibilities and evidential burden have not become simpler.

When a serious loss occurs, the outcome can still depend on three connected questions:

1. What did the policy actually say?
2. What information was presented when the risk was insured?
3. What evidence exists to establish what happened and what was lost?

Two Different Frameworks Operate at the Same Time

Commercial insurance sits at the meeting point of two different systems.

The first is the regulatory framework governing insurers and insurance intermediaries.

The second is the contractual and legal framework governing the policy itself and the relationship between insurer and insured.

The FCA regulates insurance firms. Its rules cover areas including customer communications, sales, product governance and claims handling.

For example, ICOBS 8 requires insurers within its scope to handle claims promptly and fairly, give reasonable guidance to help a policyholder make a claim, avoid unreasonable rejection and settle promptly once terms are agreed.

The commercial policyholder, however, is also entering into a contract governed by its wording and relevant insurance law.

For non-consumer insurance contracts, the Insurance Act 2015 introduced the duty of fair presentation. It also established proportionate remedies for certain failures and changed the treatment of warranties and some risk-reduction terms.

These systems are related, but they should not be confused.

A regulated broker or insurer may owe conduct obligations concerning the information and service provided.

That does not mean the provider can remain passive about its own risk.

The provider knows—or should be capable of discovering—how its services, properties, workforce, systems and activities have changed.

The authorised insurance firm can ask questions and explain the policy-specific process. It cannot create accurate operational information that the care organisation has never gathered.

Fair Presentation Is More Than Completing the Proposal Form

The Insurance Act 2015 requires a non-consumer insured to make a fair presentation of the risk before the contract is entered into.

The duty also applies before a contract is varied.

Broadly, that presentation must disclose every material circumstance the insured knows or ought to know, or provide sufficient information to put a prudent insurer on notice that further enquiries may be needed.

The presentation must be reasonably clear and accessible. Material factual representations must be substantially correct, while statements of expectation or belief must be made in good faith.

This is much broader than answering a list of renewal questions literally.

A proposal form may provide the structure.

The duty concerns the risk being presented.

For a care provider, relevant information may sit across:

• senior leadership;
• registered managers;
• HR;
• finance;
• property and estates;
• safeguarding;
• quality assurance;
• IT;
• fleet management;
• and claims records.

A person responsible for arranging the insurance may not know that:

• a service has begun undertaking additional clinical activity;
• a building extension has been completed;
• an empty room is being used for another purpose;
• agency use has increased substantially;
• a new digital platform is holding sensitive information;
• a serious incident has occurred;
• a fire-risk action remains incomplete;
• or turnover and payroll have moved beyond previous estimates.

The absence of that knowledge from the insurance file does not necessarily mean the organisation could not reasonably have discovered it.

The Reasonable Search Reaches Across the Organisation

The Insurance Act does not limit organisational knowledge to what one director, finance manager or insurance contact remembers.

For a corporate insured, knowledge held by senior management and those responsible for arranging the insurance can be attributed directly to the organisation.

The insured is also treated as knowing what should reasonably have been revealed through a reasonable search of information available to it. That information can sit within the organisation or with another relevant person, including an agent.

This is one of the most important insurance-governance points for care providers.

A renewal should not be completed as a solitary administrative task.

It should be an organised search.

The depth of that search will depend on the organisation’s scale and complexity, but the principle remains the same:

The person submitting the information needs a dependable route into the parts of the organisation where material change is most likely to be known.

For a single-location provider, that may involve a structured discussion between the owner, registered manager, finance lead and insurance contact.

For a larger group, it may require returns from:

• every registered location;
• regional operations;
• HR;
• estates;
• finance;
• cyber and information governance;
• and central quality leadership.

The output should not be a data dump.

It should be a coherent account of the risk the insurer is being asked to consider.

Clear and Accessible Does Not Mean Short and Incomplete

Commercial organisations can become trapped between two risks.

The first is under-disclosure: failing to provide important information.

The second is unstructured over-disclosure: sending large volumes of documents without identifying what they contain or why they matter.

The statutory requirement that a fair presentation be reasonably clear and accessible is significant.

An insurer should not be expected to reconstruct the provider’s risk from:

• hundreds of disconnected files;
• unexplained incident logs;
• outdated spreadsheets;
• and correspondence containing conflicting figures.

A stronger presentation separates:

• the established facts;
• material developments;
• known unresolved matters;
• estimates;
• and information still being confirmed.

It also explains movement.

If employee numbers increased, why?

If turnover rose, was it through acquisition, occupancy or a new service?

If a claim was recorded, what happened afterwards?

If a building underwent significant work, what changed in the use, value or protection of the premises?

If cyber controls improved, when were they implemented and across which systems?

Clarity gives the insurer a better opportunity to ask relevant questions.

It also gives the provider a better record of what was presented, by whom and on what basis.

Care Risk Changes Faster Than the Annual Renewal Cycle

An insurance submission captures the organisation at a point in time.

Adult social care does not remain fixed until the next anniversary.

During a policy year, a provider may:

• open or close a location;
• acquire another company;
• extend a building;
• increase bed numbers;
• add a regulated activity;
• enter a different client group;
• employ new clinical roles;
• use more agency workers;
• add vehicles;
• change fire or security systems;
• install sensors and telecare;
• introduce AI-enabled technology;
• or begin holding significantly more personal data.

Whether a particular change must be notified, when it must be notified and what consequence follows will depend on the policy and legal context.

There is no safe universal rule that every operational change is automatically covered until renewal, or that every change must always be reported immediately.

What providers need is a policy-specific change process.

The organisation should understand what the contract requires and make sure the people creating operational change know where to raise an insurance question.

A building project should not proceed on the assumption that finance will mention it at renewal.

A new service should not begin without checking how it affects the wider risk profile.

And the insurance team should not discover a material acquisition from the annual accounts months later.

The Care Provider’s Risk Profile Is More Than Its Turnover

Insurance renewals frequently ask for numerical information such as:

• turnover;
• payroll;
• bed numbers;
• resident numbers;
• employee numbers;
• vehicle numbers;
• property values;
• and claims history.

These figures matter.

But the same numbers can represent very different risks.

Two providers with identical turnover may differ because one operates:

• one modern residential home;
• and the other manages several older supported-living properties.

Two organisations with the same employee count may differ because one uses a stable permanent workforce and the other depends substantially on agency personnel.

Two services with the same number of beds may support people with very different:

• mobility;
• clinical;
• behavioural;
• and safeguarding needs.

The provider should therefore understand not only the headline figures but the operational context behind them.

This is particularly important when the business has changed without its total income moving dramatically.

A new type of care, building use or delegated responsibility may affect the character of the risk even where turnover remains similar.

What Can Happen When Fair Presentation Fails?

The Insurance Act introduced proportionate remedies for qualifying breaches of the duty of fair presentation.

The consequences differ according to the circumstances and what the insurer can show it would have done if the risk had been presented fairly.

Where a breach is deliberate or reckless, the insurer may be entitled to avoid the contract and refuse claims.

For other qualifying breaches, the remedy can depend on whether the insurer would:

• have declined the risk;
• accepted it on different terms;
• or charged a higher premium.

In some circumstances, different terms can be treated as applying. In others, a claim payment may be reduced proportionately to reflect the premium that would have been charged.

This should not be read as a prediction of what will happen in any particular dispute.

The insurer must establish the relevant breach and the counterfactual underwriting position. The facts, policy terms and evidence matter.

The point for providers is preventative:

A renewal error does not remain confined to the renewal form. Its significance may emerge only when the organisation later needs the policy to respond.

That is why disclosure should receive senior attention before the contract begins—not hurried attention after a claim has been questioned.

Policy Conditions Still Matter

Disclosure is only one part of the insurance relationship.

Policies may contain obligations concerning:

• notification;
• records;
• maintenance;
• security;
• inspections;
• protective systems;
• changes in risk;
• cooperation;
• and mitigation following a loss.

The legal effect of failing to comply with a term is not always straightforward.

The Insurance Act changed the former law under which breach of a warranty could discharge insurer liability permanently. It also restricts reliance on some terms designed to reduce a particular type of loss where non-compliance could not have increased the risk of the loss that actually occurred in the circumstances in which it occurred.

But commercial insurance contracts can contain different structures, and some statutory provisions may be capable of contractual modification where transparency requirements are satisfied.

The practical message is therefore not:

Any breach automatically invalidates a claim.

Nor is it:

The Insurance Act means policy conditions no longer matter.

It is:

The effect depends on the wording, the purpose of the term, the circumstances of the loss and the applicable law.

Policy-specific interpretation belongs with an authorised insurer or intermediary and, where necessary, a suitable legal adviser.

The provider’s operational responsibility is to know which conditions require ongoing action and make sure those actions have owners.

A Warranty Should Not Live Only in the Insurance File

Suppose the policy contains a requirement relating to:

• fire alarms;
• kitchen extraction;
• electrical inspection;
• security;
• vehicle use;
• backup arrangements;
• or vacant premises.

That requirement should not remain inside a PDF known only to finance.

It needs to reach the operational person responsible for compliance.

A property condition may need to sit within:

• the maintenance system;
• inspection calendar;
• and provider risk register.

A cyber condition may require evidence from:

• managed IT;
• system administrators;
• HR;
• and continuity testing.

A fleet condition may need to influence:

• driver authorisation;
• vehicle records;
• and training.

The insurance schedule should therefore be translated into operational accountability.

Not every policy term requires a new process.

But every material continuing condition should be capable of being evidenced.

The Claim Often Begins Before Anybody Uses the Word “Claim”

Care incidents develop in stages.

An employee may suffer an injury at work.

A person receiving care may fall.

A family may raise concerns about treatment.

Medication may be administered incorrectly.

A cyber incident may expose information.

A leak may damage several rooms.

At the beginning, the provider may not know whether the event will become:

• a complaint;
• safeguarding enquiry;
• regulatory matter;
• civil claim;
• or insurance notification.

This uncertainty can create delay.

Operational teams may believe insurance is relevant only when a solicitor’s letter or formal demand arrives.

But some policies can require notification of an event or circumstance that may give rise to a claim, rather than only a completed legal claim.

Other covers may attach according to when the underlying incident occurred.

The definitions vary and should not be generalised.

Providers therefore need an internal triage route capable of answering:

• What happened?
• Which policies could potentially be relevant?
• What notification language does each use?
• Who decides whether the threshold has been reached?
• What evidence needs to be preserved now?

This is not about notifying every minor care event indiscriminately.

It is about preventing a serious circumstance from remaining within an operational file because nobody connected it with the insurance process.

Incident Reporting and Insurance Notification Serve Different Purposes

Care providers already operate formal systems for:

• incidents;
• complaints;
• safeguarding;
• duty of candour;
• medicines;
• health and safety;
• and CQC notifications.

Those systems are essential.

CQC requires registered providers to notify it about specified changes, events and incidents. Regulation 17 also requires secure, accurate, complete and contemporaneous records concerning people’s care, employees and the management of the regulated activity.

An insurance notification is different.

It considers the event through the relevant policy wording and potential insured loss.

Submitting a CQC notification does not automatically notify the insurer.

Informing the insurer does not replace safeguarding, candour or regulatory obligations.

The strongest provider process connects these workstreams without confusing them.

A serious event may require parallel activity involving:

• the person and their representative;
• clinical leadership;
• safeguarding;
• CQC;
• health and safety;
• legal advisers;
• and the insurer or authorised intermediary.

Each route has a different purpose.

Leadership needs one coordinated chronology.

Candour and Insurance Should Not Be Set Against Each Other

Providers may worry that apologising or communicating openly could damage an insurance position.

CQC’s duty-of-candour guidance is clear that the required apology does not, by itself, mean accepting legal liability and does not affect indemnity cover. Registered providers must remain open and transparent with people when things go wrong.

This is important culturally.

Insurance should not become a reason to:

• delay communication;
• avoid an appropriate apology;
• or provide an evasive response to a person or family.

At the same time, operational communication should be accurate.

The provider should distinguish between:

• known facts;
• matters still under investigation;
• an expression of regret;
• and a concluded legal position.

The responsible approach is coordinated openness—not defensive silence or premature speculation.

Evidence Should Be Preserved Before the Story Changes

The hours immediately after an incident often contain the clearest evidence.

Over time:

• memories fade;
• rooms are repaired;
• equipment is moved;
• systems overwrite information;
• staff leave;
• and records become harder to reconcile.

Preservation does not mean creating an adversarial investigation against employees.

It means retaining the information needed to understand the event fairly.

Depending on the circumstances, relevant evidence may include:

• contemporaneous care records;
• incident reports;
• risk assessments;
• staffing and rota information;
• competence records;
• photographs;
• maintenance logs;
• equipment records;
• CCTV or access data;
• emails;
• witness accounts;
• professional advice;
• invoices;
• and a chronology of decisions.

Care records should not be amended retrospectively to make the narrative appear stronger.

Where correction or clarification is necessary, the audit trail should remain transparent.

A claim file becomes more credible when it reflects what the organisation genuinely knew and did at the time.

A Claims File Needs to Prove More Than the Event

Establishing that an incident occurred is only one part of a claim.

The provider may also need to evidence:

• causation;
• damage;
• mitigation;
• business interruption;
• additional expenditure;
• and the amount claimed.

Consider a property loss that closes part of a care home.

The organisation may need to separate:

• repair costs;
• damaged contents;
• emergency accommodation;
• additional transport;
• agency staffing;
• professional fees;
• lost fee income;
• and ordinary expenditure that would have been incurred anyway.

The fact that a cost followed the incident does not automatically establish that it falls within the insured loss.

The provider needs a clear link between:

the insured event → the operational consequence → the financial effect

That link is much easier to demonstrate when expenditure is coded and documented from the beginning.

Business Interruption Evidence Begins Before the Loss

Business-interruption claims can be complex because the provider is trying to show what financial position would probably have existed had the incident not occurred.

That can involve evidence about:

• historic income;
• occupancy;
• referrals;
• fee changes;
• wage costs;
• variable savings;
• seasonality;
• and planned operational changes.

The Enterprise Act provisions on late payment recognise that a reasonable period for claim assessment depends partly on the type, size and complexity of the claim. The explanatory notes identify business-interruption claims as an example that will often take longer to value than straightforward property-damage claims. They also note that investigation can be delayed where relevant information is not supplied promptly.

A provider cannot create reliable historic management information after a major event if it did not retain it beforehand.

Claims readiness therefore begins through ordinary financial governance:

• accurate occupancy;
• fee and income records;
• payroll;
• management accounts;
• referral pipeline;
• and documented business plans.

The insurance claim may rely on the same information leaders should already be using to run the organisation.

The Insurer Also Has Claims-Handling Responsibilities

Commercial policyholders should not interpret evidence requirements as meaning the insurer can delay or reject claims without constraint.

FCA rules require insurers within scope to handle claims promptly and fairly, provide reasonable guidance and appropriate progress information, avoid unreasonable rejection and settle promptly once terms are agreed.

Insurance contracts also contain an implied term requiring sums due to be paid within a reasonable time.

That reasonable time includes time to investigate and assess the claim and will depend on matters such as:

• the type of insurance;
• size and complexity;
• relevant rules;
• and factors beyond the insurer’s control.

An insurer may have reasonable grounds for disputing liability or amount, while its conduct in handling the claim can still be relevant to whether the implied obligation has been breached.

This creates responsibilities on both sides.

The insurer must handle the matter fairly and with appropriate pace.

The provider should supply accurate, organised information and respond to reasonable enquiries without unnecessary delay.

A disorganised claim may take longer not because the loss is invalid, but because nobody can yet establish the complete position.

Claims Should Have One Operational Owner

A claim can involve many people:

• registered manager;
• finance;
• HR;
• estates;
• quality;
• legal;
• IT;
• insurer;
• broker;
• loss adjuster;
• and external investigators.

Without one coordinating owner, communication can fragment.

Finance may send one figure.

Operations may describe a different chronology.

The registered manager may respond to factual questions without seeing earlier correspondence.

Evidence may be duplicated or contradicted.

The claims owner does not need to make every decision.

They need to maintain:

• the master chronology;
• information requests;
• agreed responsibilities;
• evidence register;
• correspondence;
• costs;
• and next action.

For a complex event, the provider should know exactly which version of the facts is current and why it changed.

This is claims governance, not administration.

A Care-Specific Example: The Fall That Develops Over Time

Consider an older person who falls within a care home.

The immediate priorities are care and safety.

Staff assess the person, obtain appropriate clinical help, inform the relevant people and record the event.

The provider then investigates whether:

• the care plan was current;
• staffing was appropriate;
• the environment contributed;
• mobility guidance was followed;
• medicines were relevant;
• equipment was available;
• and previous falls had identified a pattern.

The event may lead to:

• a complaint;
• safeguarding involvement;
• CQC notification;
• duty-of-candour action;
• or later correspondence alleging that the provider was responsible.

The insurance significance may not be apparent on the first day.

The evidence created on the first day may later be decisive.

A strong file does not attempt to manufacture a defence.

It shows:

• what the person’s needs were;
• what staff knew;
• what happened;
• how the provider responded;
• what was learned;
• and what changed afterwards.

That is simultaneously stronger care governance and stronger claims evidence.

A Care-Specific Example: The Water Escape That Becomes a Continuity Event

A pipe fails overnight and damages several rooms.

At first, the incident appears to be a property repair.

The operational effect expands.

People need to be relocated within the building.

Additional staff are required.

Some equipment is damaged.

A room cannot admit a planned resident.

Laundry and electrical systems are affected.

A specialist contractor attends out of hours.

The provider needs to distinguish:

• the physical damage;
• emergency mitigation;
• temporary operating costs;
• loss of income;
• ordinary maintenance;
• and improvement work undertaken at the same time.

The claims file must connect each cost with the event.

The operational file must show that people remained safe.

If those records are created through separate teams without coordination, the provider may later struggle to explain both the loss and the response.

Claims History Should Be Analysed, Not Merely Listed

Renewal processes often request a claims history.

A list of dates, causes and payments provides limited insight.

Provider leadership should understand what the history reveals about the operation.

Repeated claims may indicate:

• one recurring property defect;
• inadequate incident learning;
• weak manual-handling controls;
• an unstable workforce;
• unsuitable vehicles;
• poor claims reporting;
• or simply a service profile carrying inherently higher exposure.

The organisation should be able to explain what changed following material incidents.

This does not guarantee a particular underwriting decision.

It demonstrates that the provider understands its own loss experience.

A claims register should therefore capture:

• the event;
• current status;
• reserve or payment information where available;
• operational cause;
• corrective action;
• and whether similar events recurred.

The register becomes a risk-management tool rather than an annual attachment.

Renewal and Claims Should Be Connected

The people managing claims often know which risks are changing.

The people completing renewal often know which information the insurer has requested.

Those functions should not operate separately.

A material incident may affect:

• the claims history;
• operational controls;
• property information;
• anticipated litigation;
• or future risk presentation.

Similarly, questions raised at renewal may expose areas where claims evidence is weak.

The provider should hold a pre-renewal meeting that examines:

• open claims;
• unresolved circumstances;
• serious incidents;
• regulatory action;
• major complaints;
• property change;
• workforce movement;
• cyber developments;
• and acquisition or closure plans.

The aim is not to report every issue as though it were equally material.

It is to ensure that the organisation has made a conscious, documented decision about what needs to be presented.

The Authorised Intermediary Can Support the Process—but Cannot Own the Provider’s Facts

FCA-regulated brokers acting for commercial customers are subject to requirements concerning customer interests, conflicts and clear information.

The FCA states that firms should provide appropriate policy information in good time and in a comprehensible format so the customer can make an informed decision. A commercial customer can also request disclosure of broker commission, including relevant forms of remuneration.

That regulatory position does not turn the broker into the provider’s operational risk manager.

The provider remains best placed to know:

• what services it operates;
• how its property is used;
• what activities staff undertake;
• and what incidents have occurred.

A productive intermediary relationship depends on both sides being clear about responsibility.

The provider supplies accurate and complete organisational evidence.

The authorised firm asks relevant questions and provides policy-specific information within its role.

Care Circle Network’s role remains informational.

It can explain this relationship generally.

It cannot tell an individual provider which contract, insurer, limit or term is appropriate.

Insurance Governance Should Sit at Board Level

Insurance is often reported to boards through three figures:

• renewal date;
• premium;
• and claims total.

That is not enough to understand the protection or the risk.

Boards, owners and nominated individuals should also know:

• which entities and locations are insured;
• how operational change reaches the renewal process;
• who signed off the fair presentation;
• which continuing conditions require evidence;
• which claims or circumstances remain open;
• where declared values came from;
• and which loss scenario could cause the greatest uninsured operational disruption.

Insurance should be discussed alongside:

• quality;
• property;
• cyber;
• workforce;
• and business continuity.

It is not a separate financial product sitting outside those risks.

It is one of the mechanisms through which part of their financial consequence may be transferred.

A Practical Insurance Clarity Review

A provider does not need to wait for renewal or a claim to test its current position.

During the first stage, leaders should compare the policy schedule with the organisation as it exists today.

Are all legal entities, locations and activities represented accurately?

Have acquisitions, closures, refurbishments or service changes occurred?

Do payroll, turnover and occupancy assumptions remain credible?

The second stage should follow several significant incidents from the operational system into the insurance process.

Was each event considered for notification?

Who made the decision?

Is the evidence still accessible?

Does the claims register agree with the insurer’s record?

The third stage should translate important policy conditions into operational ownership.

A fire-protection requirement belongs with estates.

A cyber-control declaration needs confirmation from IT and management.

A vehicle-use condition should connect to fleet procedures.

The final stage should test one claims scenario.

Can the organisation find the policy, notify the correct contact, preserve evidence and begin recording additional costs without relying on one absent employee?

The purpose is not to simulate legal proceedings.

It is to expose preventable uncertainty.

Ten Questions Care Leaders Should Be Able to Answer

1. Who is responsible for coordinating the organisation’s fair presentation of risk?
2. What constitutes the reasonable search across our services and departments?
3. Which operational changes trigger an insurance review before renewal?
4. Are the statements made in the latest submission still accurate in practice?
5. Which policy conditions require continuing evidence from operational teams?
6. Who decides whether an incident, circumstance or claim should be notified?
7. Can we produce a coherent chronology and evidence file for every material loss?
8. Do our regulatory, legal and insurance communications tell a consistent factual story?
9. Which open claims or disputes could affect the next renewal?
10. What information would we struggle to prove if a serious event occurred tonight?

The final question is the real test of claims readiness.

Simpler Rules Do Not Mean Simpler Risk

The FCA’s direction is towards a more proportionate and less duplicative insurance rulebook.

That may allow insurers and intermediaries to remove unnecessary process and communicate more flexibly.

It should not be interpreted as a reduction in the importance of:

• policy clarity;
• accurate disclosure;
• operational compliance;
• or claims evidence.

The summer changes were primarily changes to regulated-firm requirements.

The Insurance Act remains relevant to commercial policyholders.

The contract remains specific to the organisation.

And the facts of a loss still need to be established.

For care providers, the real opportunity is not to become insurance lawyers.

It is to become better organised around the information only they can own.

They need to know:

• what their operation has become;
• what changed since the previous renewal;
• what the policy expects during the year;
• what incidents may require escalation;
• and what evidence will survive after the event.

A well-run insurance process should feel familiar to a care provider.

It depends on the same qualities expected elsewhere:

• accurate records;
• clear accountability;
• contemporaneous evidence;
• open communication;
• and action based on changing risk.

The claim does not begin when the form is submitted.

It begins with the way the organisation understood and documented the risk before anything went wrong.

Insurance rules changed in July.

The fundamentals did not.

Clarity matters.

Disclosure matters.

Evidence matters.

And when care continuity may depend on the outcome, those responsibilities deserve more than an annual signature.

Frequently Asked Questions

What insurance rules changed in July 2026?

The FCA completed part of a package simplifying and clarifying sections of its Handbook. Most of the relevant insurance changes took effect on 26 June, with remaining parts on 27 July. The measures included removal or rationalisation of outdated and duplicative requirements. Further simplification proposals published in June remained under consultation.

Did the FCA changes remove a business’s disclosure responsibilities?

No. The FCA changes concerned the regulatory framework applying to insurance firms. Non-consumer policyholders remain subject to the Insurance Act 2015 duty of fair presentation when entering into or varying an insurance contract.

What is a fair presentation of risk?

Broadly, it requires disclosure of material circumstances the insured knows or ought to know, or enough information to put a prudent insurer on notice to investigate further. The presentation must be reasonably clear and accessible.

Does completing an insurer’s questionnaire automatically satisfy the duty?

Not necessarily. The legal duty concerns the presentation of the risk. A provider may need to undertake a reasonable search of information across senior management, insurance personnel and relevant parts of the organisation.

What can happen if important risk information is omitted?

The outcome depends on whether there was a qualifying breach, whether it was deliberate or reckless and what the insurer would have done if the risk had been presented fairly. Potential remedies can include avoidance, different terms or a proportionate reduction in payment.

Must every care incident be notified to an insurer?

No general answer applies to every policy. Notification requirements and definitions differ. Providers need a process for checking significant incidents, claims and potential circumstances against the relevant wording.

Does notifying CQC also notify the insurer?

No. Regulatory notification and insurance notification are separate processes serving different purposes. Providers must consider each applicable route independently.

Does an apology under the duty of candour admit legal liability?

CQC states that the apology required under duty-of-candour arrangements does not, by itself, mean accepting liability and does not affect indemnity cover.

What evidence should be preserved after a serious event?

The relevant evidence depends on the event, but may include contemporaneous records, photographs, witness accounts, risk assessments, staffing information, maintenance records, invoices and a clear decision chronology.

What obligations does an insurer have when handling a claim?

FCA rules require insurers within scope to handle claims promptly and fairly, provide reasonable guidance, avoid unreasonable rejection and settle promptly after terms are agreed. Insurance law also implies a requirement to pay sums due within a reasonable time, allowing for proper investigation and assessment.

Editorial note

This feature provides general information about insurance regulation, commercial insurance contracts and claims readiness. It does not constitute insurance, legal or financial advice, a personal recommendation, or an assessment of any organisation’s insurance needs. Policy wording, duties, exclusions, conditions and claims outcomes vary. Providers should obtain policy-specific information from an appropriately authorised insurance intermediary, insurer or relevant professional adviser.

Editorial sources

This feature has been developed using information available by 27 July 2026, preserving the integrity of its backdated publication position.

• Financial Conduct Authority, CP26/22: Simplifying the Insurance Rules, published June 2026.
• Financial Conduct Authority, Handbook Notice No. 142, June 2026.
• Financial Conduct Authority, PS25/21: Simplifying the Insurance Rules.
• Financial Conduct Authority, ICOBS 8: Claims Handling.
• Financial Conduct Authority, General Insurance Brokers: Acting for Commercial Customers.
• UK Parliament, Insurance Act 2015.
• UK Parliament, Enterprise Act 2016: Late Payment of Insurance Claims.
• Care Quality Commission, Regulation 17: Good Governance.
• Care Quality Commission, Notifications for Providers.
• Care Quality Commission, Duty of Candour Guidance.

Author: CSN Editor