Accepting a claim is not the same as fully assessing the damage. A claim can be covered by the policy and the proposed repairs can still leave real damage unaddressed. That gap is the part of the consumer insurance debate we see most often, and nobody currently measures it.
That is not only our view. In its written evidence to the House of Lords Financial Services Regulation Committee (CIM0039, 22 July 2026), Which? told the Committee that the poor practices found in motor total-loss claims “suggested there may be wider issues on claims where the fair value is more contestable, such as major repairs to a property”. It also said a more systematic analysis of ombudsman decisions is needed to identify “the scale of unfairly low claim payouts”, because that scale is currently unknown.
Major repairs to a property are our work. This article sets out what we see in that space, and why it belongs in the inquiry’s evidence.
What the Committee is examining
The Committee’s inquiry into the regulation of the consumer insurance market covers how home and travel insurance is sold, how claims are handled and how disputes are resolved.
On 2 September 2026 it heard from David Geale, Executive Director of Consumers, Payments and Competition at the FCA, and Chris Knight, Director of Insurance at the FCA. It then heard from James Dipple-Johnstone, Chief Ombudsman at the Financial Ombudsman Service, and Rachel Lam, Interim Ombudsman Managing Director. Earlier sessions heard from insurers, brokers, comparison websites and consumer representatives, including Which? on 17 June 2026.
These sessions examine how the market is regulated. They are not findings that every declined claim is wrong or that every insurer is failing its customers. Insurers remain entitled to investigate whether a loss is covered and to apply the policy terms fairly.
How the Which? super-complaint fits in
Which? submitted a super-complaint to the FCA about poor claims handling and confusion over what home and travel policies cover. The FCA responded on 18 December 2025, accepting the complaint and announcing five new and expanded areas of work. It has committed to publish a progress update by the end of 2026.
Responding to the launch of the Lords inquiry on 21 May 2026, Rocio Concha, Which? Director of Policy and Advocacy, said the announcement was “a direct result of the concerns Which? raised”.
One of the FCA’s five commitments is to consider how it captures claims outcomes in its review of the value measures rules. That is the commitment most relevant to what follows, because outcome data is where the current picture is thinnest.
The data records decisions, not adequacy
Published data tells us how often claims are accepted and how often complaints are upheld. It does not tell us whether a settlement covered the work.
For January to March 2026, the Financial Ombudsman Service recorded 1,726 new buildings insurance complaints and a 38% uphold rate for buildings insurance complaints resolved in that quarter. The average uphold rate across all products was 28%. Buildings insurance sits well above that average, though the complaints received and the complaints resolved are not necessarily the same cases, and the figure does not mean 38% of home insurance claims were handled incorrectly.
Which? reported to the Committee that only 63.2% of buildings-only claims were accepted in 2024, and that a bespoke FCA data request found around one in three storm claims accepted that year. It noted that the value measures “currently only provide headline figures”.
None of that captures the claim that was accepted, paid and still left the property short. A settlement that is too low does not become a statistic until someone challenges it.
Why the repair assessment decides the settlement
In the claims we handle, a disagreement about the settlement figure usually starts as a disagreement about the work required. Before repairs can be priced, someone has to establish what caused the damage, how far it has spread and which materials can be retained.
A photograph or a video call can be useful. Neither will show moisture beneath a tiled floor or mould behind plasterboard. Where there is evidence of concealed damage, further investigation is needed before the repair schedule is agreed.
An early assessment is not automatically unreasonable. It may reflect the information available at the time. The question that matters is whether the insurer revisits that assessment when further evidence appears. This is the same reinstatement gap that surprises homeowners after the offer arrives.
The two claims below are our own work. They are selected examples, not a survey of the market, and they are not a guide to what any other claim would settle at.
An accepted claim that still needed review
In a Perthshire storm claim, the insurer accepted that the damage was covered and initially offered £3,000. The proposed works did not properly allow for the roof damage, safe access or the internal repairs needed after rainwater entry.
After we reviewed the scope and challenged the offer, the claim settled at £15,000. Cover was never the dispute. The scope of works was. In the published data this claim would appear only as an accepted storm claim, at either figure.
Concealed damage that changed the loss
A heating pipe failed beneath the ground floor of a Belfast home. The insurer’s loss adjuster inspected the bathroom and offered £6,000, without investigating whether water had travelled beneath the adjoining tiled areas.
We carried out a moisture survey across the ground floor. The concrete slab and flooring were saturated well beyond the bathroom, and the tiled surface had concealed it. We prepared a room-by-room schedule of works supported by photographs and moisture mapping. The claim settled at £73,000, with alternative accommodation agreed while the property was reinstated.
The revised figure followed evidence of a much wider loss. Nothing about the policy changed.
A Falkirk claim shows the same point at the other end of the process. A drying certificate had been issued, but mould was later found on the studwork behind retained plasterboard. A completed drying programme is not the same as a resolved repair scope.
What a settlement review should establish
There is no need to wait for the inquiry to ask sensible questions about a claim. Under ICOBS 8.1.1R, an insurer must already handle claims promptly and fairly, give reasonable guidance and appropriate progress information, not unreasonably reject a claim, and settle promptly once terms are agreed.
Before a final settlement is accepted, four things are worth establishing:
- the damage, including whether the assessment covered all affected areas and any concealed damage the evidence justifies investigating
- the repairs, including what will be removed, retained and reinstated, with access and associated work allowed for
- the policy, including how any exclusion, limit, excess or underinsurance deduction applies to this claim
- the evidence, including photographs, reports, readings and correspondence, and the specific point in dispute
A lower offer is not automatically unfair, and not every claim needs professional representation. Where the damage is substantial, the shortfall is unexplained or the policy wording is in dispute, independent advice helps clarify the position before anything is agreed. Delay and repeated requests for information are common features of difficult claims rather than proof of bad faith. Which? found that claims involving third parties were nearly twice as likely to run into problems as those without them.
What happens next
As at 10 September 2026, the Committee has not published its final report. Its conclusions and any recommendations will need to be considered when they are available, and it would be premature to promise changes to claims-handling rules or to individual settlements.
Our view is that scrutiny of claims outcomes should look beyond whether a payment was made. The practical test is whether the insured damage was properly investigated and whether the settlement reflects the work the policy requires. Clear policy wording matters. So does a sound assessment of the damaged property, and only one of those is currently counted.
If the FCA does capture claims outcomes in its value measures review, the useful measure is not how many claims were paid. It is how many were scoped correctly the first time.
Independent help with a property claim
PCLA acts for policyholders across Northern Ireland and Scotland’s Central Belt. Our loss assessors review the policy, inspect the damage, prepare the evidence and deal with the insurer and its appointed loss adjuster on your behalf.
If a claim has been delayed, rejected or offered for less than the repairs require, contact PCLA for an initial discussion. We will explain whether our help is appropriate. We act for you, not your insurer.
