After more than a year of investigation, consumer watchdog Which? has issued a formal super-complaint to the Financial Conduct Authority (FCA), calling out systemic failings in the home and travel insurance markets.
The complaint comes after Which? research revealed widespread problems in how policies are sold and explained, and how claims are handled. With tens of millions of customers relying on these policies, the findings highlight issues that go beyond individual firms to the structure of the market itself.
Why has Which? made a super-complaint?
A super-complaint is a legal tool available to certain consumer bodies when they believe entire markets are harming customers. It’s not about one company, but about systemic consumer detriment.
This is only the second time in a decade that Which? has used this power, the last was in 2016 over banks’ handling of transfer fraud. That case eventually led to new laws protecting victims.
Which? argues that a similar intervention is now needed in insurance, where claims acceptance rates are among the lowest in the sector and regulatory oversight has so far failed to fix the problems.
Find out more: learn about Which’s? campaign to end the insurance ripoff
What Which? found
hrough four detailed reports, original research, and hundreds of consumer stories, Which? has uncovered recurring patterns:
- Rejected or delayed claims – Customers report being left in financial hardship, with claims refused on technicalities or slowed by poor service.
- Confusing policies – Terms and exclusions are difficult to understand, leaving people unsure what they’re really covered for.
- Lack of regulatory enforcement – While the FCA has acknowledged “substandard service levels” and “too many examples of customers not receiving the service they’re entitled to,” Which? says it has yet to act decisively.
Case studies: when insurance failed
A holiday that ‘technically took place’
In 2023, Northampton traveller Yvette Greenley was due to fly to Egypt. After her plane turned back to Luton due to a fault, she missed the holiday entirely. But her insurer initially ruled the holiday had “technically taken place,” denying her claim. Only after Which? intervened was the claim paid in full, with additional compensation.
A house fire with no clear way home
In 2024, Kaja and Dean Cordwell’s home was badly damaged in a fire. Nearly two years later, they remain locked in disputes with their insurer over delays and settlement amounts. They told Which? the process has left them feeling “gaslighted” while still unable to properly return home.
These are not isolated examples. Which? says such stories reflect wider failings in how insurers manage claims and support vulnerable customers.
Read more about these case studies on Which? launches insurance ‘super-complaint’ – Which?
What Which? is calling for
In its super-complaint, Which? asks the FCA to take three decisive actions:
- Enforcement – Intervene urgently where insurers are failing to meet legal obligations.
- Market study – Investigate why home and travel insurance consistently deliver poor outcomes.
- Review consumer protections – Work with government to ensure existing safeguards are fit for purpose.
The FCA must respond within 90 days, with options ranging from enforcement and new rules, to commissioning further studies, or taking no action at all.
Reaction from industry and experts
- Which?’s Director of Policy and Advocacy, Rocio Concha, called this a “major intervention,” adding:
“Serious failings in home and travel insurance have been tolerated for too long … this super-complaint should mark a turning point that leads to fundamental changes in how insurers treat their customers.”
- Mark Wilkinson, Managing Director at Norton Insurance Brokers, commented:
“This super-complaint highlights what many customers already feel that the insurance industry has too often lost sight of service. At Norton, we see our role very differently. Insurance is a promise, and when a customer makes a claim, it’s the moment that promise should matter most. Transparency, fairness and genuine support are non-negotiable. We welcome Which?’s call for higher standards and believe this is an opportunity for the industry to rebuild trust with policyholders.”
- Martin Lewis, founder of MoneySavingExpert, backed the move, highlighting the “imbalance of power” between firms and consumers. He noted research showing travel insurers charging six to 27 times more for customers with a history of severe bipolar disorder, despite questionable justification.
- The Association of British Insurers (ABI) responded that insurers “take their responsibility to protect their customers incredibly seriously,” pointing out that in the first half of 2025 alone, insurers paid £1.7bn on 300,000 home claims and £472m on 500,000 travel claims.
What consumers can do now
Which? advises customers who feel unfairly treated to:
- Check your policy wording – Know what’s covered and watch for exclusions.
- Declare vulnerabilities – Let your insurer know if you have health, financial or personal circumstances they should consider.
- Make a formal complaint – Write clearly what went wrong and what resolution you expect.
- Escalate to the Ombudsman – If unresolved after eight weeks, the Financial Ombudsman Service can independently review your case.
What happens next?
The FCA’s response will shape whether this complaint becomes a turning point or a missed opportunity. Enforcement action could reset standards across the market, while inaction risks leaving consumers facing the same confusion and unfair treatment.
For now, Which?’s intervention shines a spotlight on an industry that, for too many, is adding stress rather than relief in times of crisis.
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