The action plan outlines the insurance industry’s position on the remaining recommendations from the Parliamentary flood inquiry and the independent review of the industry’s Code of Practice. 

Of the 150 recommendations for insurers, 109 are agreed or agreed in principle, 28 require further investigation by industry, 10 require individual insurers to determine the practicality or appropriateness of implementation, and three are not supported. The three recommendations that are not supported all relate to pricing. The plan provides seven areas of focus and key commitments. 

The industry does not consider that the Code of Practice is an appropriate mechanism to determine pricing, and, more importantly, has concerns that what is proposed by these recommendations is likely to be in breach of competition laws given the restrictions on insurers collectively reaching an agreement on pricing practices.

The plan also includes the industry’s response to recommendations made by the Parliamentary inquiries into the impacts of climate change on premiums and financial abuse.

Areas of focus

1. Vulnerability – the industry will develop a vulnerability framework that supports insurers to consistently identify and better support customers in need.
2. Claims and complaints handling – insurers will review their claims processes and make adjustments available to improve responsiveness and the customer experience.
3. Transparency – the industry will investigate the best mechanisms for communicating risk to consumers and to help them understand their premiums.
4. Product design – insurers will consider product design recommendations individually to ensure availability of competitive and innovative products.
5. Governance – insurers will explore how small businesses can be better supported by the Code.
6. Affordability – the industry will continue to work collaboratively with governments at all levels to support solutions to the protection gap and ensure effective investment in mitigation.
7. Enhancing preparedness for natural disasters – the industry will continue to make improvements to their planning, communications and operations to build in resilience to disasters.