General Insurance Value Measures: What the FCA's Review and CP26/33 Mean for Firms

The Financial Conduct Authority (FCA) has concluded that the general insurance value measures rules are broadly working as intended, but that inconsistent reporting is limiting the usefulness of the data. In Consultation Paper CP26/33, published in September 2026, it proposes removing two data fields from the annual value measures return and signals wider changes to definitions and reporting, on which it expects to consult in the first half of 2027. Comments on the current proposals are due by 9 October 2026.

The paper combines the FCA's post-implementation review of the value measures rules, introduced through Policy Statement PS20/9 and in force since 2021, with a short consultation on amendments to SUP 16.27. It is relevant to insurers, intermediaries and managing agents that report value measures data, and to Gibraltar-based and Temporary Permission firms where the rules apply to them. The proposals are modest. The more significant message concerns data quality: the FCA states that firms should have internal checks and controls over their reporting, and that it will consider supervisory action where there is a risk of non-compliance.

What Did the FCA's Review of Value Measures Find?

The review drew on a survey of 48 reporting firms, an industry working group of trade bodies and 16 firms, two consumer organisations and the FCA's supervisory experience. The FCA did not attempt to isolate the causal impact of the rules, so the findings describe how the data is used rather than measure consumer benefit. For scale, the 2025 value measures data covered 174 firms reporting £36bn of premiums across 153m policies and 37 product lines, excluding products with fewer than five firms reporting.

Firms value the data, mainly for governance and fair value

In the FCA's survey, 90% of firms said value measures had a positive or somewhat positive impact in addressing harms, encouraging comparison of product performance and improving transparency. Most use the data in internal governance, peer benchmarking and as an input to fair value assessments under the Product Intervention and Product Governance sourcebook (PROD), and some include it in board and committee reporting.

There is a qualification. Some firms said value measures have become less central since the General Insurance Pricing Practices fair value rules in 2022 and the Consumer Duty in 2023, and that they now rely on more granular metrics such as cancellations, loss ratios and reasons for declined claims.

The FCA uses value measures to identify outliers

For the FCA, value measures are a supervisory tool used alongside other intelligence to identify outliers and emerging harms. The clearest example is guaranteed asset protection (GAP) insurance: when the 2022 data showed only 6% of GAP premiums being paid out in claims, the FCA warned firms, and most insurers paused GAP sales until they had redesigned their products.

Reporting consistency is the central weakness

Around half the firms surveyed said the rules were not clear enough to enable consistent reporting, and some believed competitors were not reporting in line with the requirements. The FCA's July 2026 data publication had already said home insurance claims acceptance rates should be used with caution, and for the 2025 data it followed up with 32 of the 174 firms whose data it published. The main sources of inconsistency identified were:

• the definition of a claim, which includes "queries in respect of a potentially claimable event or loss (which has taken place)", so that some enquiries and claims below the excess are recorded as rejected;

• distinguishing claims from enquiries across online, app and telephone channels, including abandoned online claims;

• a timing mismatch between policies sold and claims paid in the same calendar year, particularly for multi-year products;

• claims with several heads being reported as accepted if any part is paid; and

• inconsistent treatment of add-ons, standalone products and cover options, such as home emergency cover.

  
  

Several firms also warned that the breadth of the claim definition could create an incentive to minimise the capture of genuine enquiries. Firms should consider that risk from a Consumer Duty perspective as well as a reporting one.

What Is the FCA Proposing in CP26/33?

The consultation is deliberately narrow. The FCA proposes two amendments to SUP 16.27, which it says will reduce burden without materially reducing the usefulness of the data:

1. Removing the requirement to report the amount that the top 2% of claim pay-outs are above (SUP 16.27.11R(11)). The FCA does not publish this metric or use it widely, firms rated it the least helpful, and the FCA has seen it calculated incorrectly.

2. Removing the requirement to report the names of the five largest distribution arrangements for each product (SUP 16.27.11R(12)), deleting the related definition in SUP 16.27.6R. Again, the FCA neither publishes nor widely uses this data.

   
   

The draft instrument makes corresponding changes to the REP019 form and completion notes in SUP 16 Annex 48AR and Annex 48BG, and does not propose changes to other data fields.

Implementation and transitional arrangements

These are consultation proposals, not final rules. If made as proposed, the changes would take effect for the 2026 data due by 28 February 2027, with a transitional period:

• 2026 data, due by 28 February 2027: reporting both fields is optional.

• 2027 data, due by 28 February 2028: reporting both fields remains optional.

• 2028 data, due by 28 February 2029, and later years: neither field should be included.

  
  

The optional period is intended to spare firms short-term system changes ahead of wider reforms. The commencement date of the instrument has not yet been set.

What Could Change When the FCA Consults Again in 2027?

The larger changes are still to come. The FCA launched an industry working group in July 2026 and expects to consult on wider changes in the first half of 2027. None of the following is yet a proposal. The FCA has said it will consider clearer metrics and definitions, including the definition of a claim; reporting some data on an earned or incurred basis; closer alignment with the complaints reporting product categories introduced by PS25/19; and publishing more of the data, more often.

The FCA also notes that artificial intelligence (AI) tools can present published value measures data to consumers without the context needed to interpret it, which reinforces the case for consistent reporting. We looked at consumer use of AI more widely in our article on the FCA Mills Review.

Key Themes for General Insurance Firms

Three broader messages emerge.

1. First, the accuracy of value measures reporting is a governance matter, not an administrative one. The FCA expects internal checks and controls over the return and may carry out deeper dives into claims handling and reporting processes where it sees a risk of non-compliance. Published data is read by supervisors, consumer groups and AI tools, so errors carry reputational consequences too.

   
   

2. Second, value measures are one input into fair value, not the whole picture. The FCA does not use the data in isolation, and other evidence it cites points to weaker claims experiences: in its 2024 Financial Lives survey, 79% of adults who had claimed in the two years to May 2024 said their most recent claim was completely successful, down from 84% in 2020. Fair value assessments and Consumer Duty outcomes monitoring should draw on wider claims management information.

   
   

3. Third, the 2027 consultation is the more consequential event. Firms that tighten claims classification and data controls now will be better placed to absorb changes to definitions or reporting bases.

What Should Firms Do Now

For most reporting firms a proportionate review is enough, and much of it can sit alongside normal preparation of the 2026 return. We suggest the following steps:

• Decide by 9 October 2026 whether to respond, particularly if the two fields are costly to produce or you have views on the transitional approach.

• Decide whether to keep reporting the two fields for 2026 data, record the reasoning and tell everyone who contributes to the return, including business partners.

• Test how claims and enquiries are classified against the SUP 16.27 definition across every channel, including claims below the excess and claims handled by third-party administrators.

• Check that add-on, standalone and cover option allocations are consistent with previous years, and document the rationale.

• Strengthen controls over the return, with reconciliation to source systems, variance analysis against the previous submission and a documented senior sign-off.

• Make sure fair value assessments and board reporting use value measures alongside more granular information such as claims timeliness, complaint root causes and walkaways.

• Include REP019 in your compliance monitoring plan and allocate responsibility for tracking the 2027 consultation.

  
  

Frequently Asked Questions

What are general insurance value measures?

General insurance value measures are annual data that firms report to the FCA on the REP019 return under SUP 16.27 for a wide range of retail general insurance products. The FCA publishes claims frequency, claims acceptance rates, average claim pay-out and claims complaints as a percentage of claims by firm and product. The rules were introduced by PS20/9 and have applied since 2021.

What is the FCA proposing in CP26/33?

The FCA proposes removing two value measures reporting requirements: the amount that the top 2% of claim pay-outs are above, and the names of the five largest distribution arrangements for each product. The proposals are open for consultation until 9 October 2026 and are not yet final rules.

When would the changes take effect?

If confirmed, reporting the two fields would be optional for the 2026 and 2027 data, due by 28 February 2027 and 28 February 2028 respectively. From the 2028 data, due by 28 February 2029, firms should not include them. The FCA has not yet set a commencement date for the instrument.

What did the FCA's post-implementation review of value measures find?

The FCA found that the rules have improved transparency, supported firms' fair value assessments and strengthened its supervision, with 90% of surveyed firms reporting a positive or somewhat positive impact. However, around half said the rules were not clear enough to enable consistent reporting.

Is the FCA planning wider changes to value measures reporting?

Yes. Working with an industry working group launched in July 2026, the FCA expects to consult on wider changes in the first half of 2027. Areas under consideration include clearer definitions, reporting some data on an earned or incurred basis and publishing more data. No specific proposals have yet been made.

How Compliance Angle Can Help

Compliance Angle supports general insurance firms in meeting the FCA's reporting, product governance and Consumer Duty expectations. Relevant support includes:

• reviewing value measures processes and controls, and building REP019 into monitoring plans, as part of ongoing compliance support and monitoring;

• documenting reporting procedures, claims classification rules and sign-off arrangements within your FCA compliance framework and policies;

• integrating value measures and wider claims information into fair value assessments and outcomes monitoring through our Consumer Duty support;

• reviewing governance and board reporting through our FCA risk management and governance service; and

• compliance training for claims and reporting teams on classifying and recording customer contacts.

Our support is practical and proportionate to each firm's business model, permissions, size and regulatory risk. If you would like to discuss how CP26/33 affects your value measures reporting, please contact us at info@complianceangle.co.uk.

Source: Financial Conduct Authority, CP26/33: Consultation on minor General Insurance value measures changes and Post-implementation review of the value measures rules, September 2026.