Most homeowners only discover how their insurance really works when something goes wrong.
A burst pipe, storm damage, a fire or flood is often the first time a policy is properly tested. That moment — the claim — is where expectations meet reality. It’s also why a recent development from Which? has attracted attention across the insurance sector.
Which? has submitted a super-complaint to the Financial Conduct Authority (FCA), arguing that parts of the UK insurance market are delivering persistently poor outcomes for consumers. This is not a routine press release or commentary. A super-complaint is a formal regulatory mechanism that requires the FCA to investigate and respond.
The FCA has until 23 December to publish its response.
This article explains what the complaint is really about, why regulators care, and what it may signal for homeowners like yourself.
What is a super-complaint, and why does it matter?
A super-complaint can only be made by a designated consumer body, such as Which?. It is designed for situations where there is evidence of system-level consumer harm, rather than isolated disputes or individual firms falling short.
In simple terms, it forces regulators to look beyond one-off complaints and ask whether a market is working as intended.
For homeowners, the significance lies not in the legal process itself, but in what has prompted it. Which? is not focusing on minor service frustrations. The complaint centres on claims outcomes — what actually happens when people try to rely on their insurance.
What the Which? complaint is really about
There has been some misunderstanding about the scope of the complaint.
- It is not an allegation that insurers should pay every claim.
- It is not about one insurer behaving badly.
- And it is not primarily about customer service tone or call-handling delays.
Instead, Which? is asking regulators to examine whether the home insurance market is consistently delivering outcomes that match reasonable consumer expectations. The issues highlighted include:
- Claims acceptance rates that are materially lower than in other types of insurance;
- Settlement practices that may leave homeowners short of full reinstatement;
- Consumer confusion about what is — and is not — covered until a claim is made.
These are precisely the issues regulators care about because they sit at the intersection of product design, claims handling, and consumer understanding.
Acceptance rates, expectations, and trust
One of the most widely cited data points behind the complaint is claims acceptance rates.
Home insurance claims, particularly buildings-only and combined buildings and contents claims, are accepted at lower rates than many other mainstream insurance products. This does not mean those claims should have been paid. Insurance is a contract, and exclusions exist for a reason.
However, from a regulatory perspective, consistently lower acceptance rates raise an important question: is there a growing gap between what homeowners expect and what policies actually deliver?
For most people, a home insurance claim is a once-in-a-lifetime event. They’re unlikely to be familiar with technical definitions, evidence requirements, or how causation is assessed. When a claim is declined, the experience can feel abrupt or confusing, even when the insurer believes it is acting correctly.
Trust in insurance is built — or lost — at this point.
Cash settlements: flexibility versus confidence
Another area receiving closer attention is the use of cash settlements.
When handled properly, cash settlements can work well. They can offer speed, flexibility, and control, particularly where homeowners prefer to manage repairs themselves or use trusted contractors.
The challenge is not the concept of cash settlements, but how settlement values are assessed.
Insurers will often calculate settlement figures using rates available within their own repair networks or supply chains. Homeowners arranging work independently may have no clear benchmark to judge whether a proposed figure genuinely reflects the cost of fully reinstating their property.
Without that reference point, a settlement that looks reasonable can later prove insufficient.
This is why valuation — not settlement type — is increasingly part of the regulatory conversation. Ensuring that a settlement reflects full entitlement under the policy is central to delivering fair outcomes.
The quieter issue: how claims are governed
One of the less visible themes behind the super-complaint is claims governance.
Modern insurance claims often involve multiple parties: insurers, loss adjusters, surveyors, contractors, and repair networks. Outsourcing itself is not a problem, but fragmentation can create gaps in accountability.
This is why some homeowners experience delays, repeated requests for information, or inconsistent communication, even where no party is acting in bad faith. Responsibility can become diffused, and resolution slows.
From a consumer’s perspective, the experience feels personal. From a system perspective, it is structural.
Understanding this distinction matters, because it explains why frustration is often widespread rather than isolated.
Why regulators are sharpening their focus now
The regulatory backdrop has also shifted.
Under the FCA’s Consumer Duty, firms are expected to demonstrate not just that they follow the correct steps, but that customers receive good outcomes. Process alone is no longer enough if the end result consistently falls short of expectations.
This does not mean regulators expect insurers to ignore policy terms. It does mean that how policies are designed, explained, and applied at claim stage is under greater scrutiny.
The Which? super-complaint should be seen in this context. It reflects a broader regulatory emphasis on transparency, understanding, and outcomes — particularly in high-impact moments such as home insurance claims.
What this signals for homeowners
For homeowners, this is not a reason for alarm. It is a signal.
It suggests that claims outcomes are receiving closer attention, and that understanding how the system works is increasingly important. A home insurance policy is not just a document purchased at renewal; it is a framework that only truly matters when something goes wrong.
When a claim is complex or high-value, many homeowners choose to seek independent help to understand their position, interpret policy wording, and ensure their claim is assessed properly. That is not about conflict. It is about clarity and balance.
If you’re unfamiliar with the role of an independent Loss Assessor, our guide to what a Loss Assessor does and when to use one may be helpful.
A moment of scrutiny, not a verdict
The FCA’s response to the super-complaint, due by 23 December, will be closely watched. It’s unlikely to be a single dramatic intervention. More often, change in insurance happens through incremental scrutiny, guidance, and oversight.
For consumers, the most important takeaway is simple: understanding your policy, your entitlement, and your options matters — especially at claim stage.
The Which? super-complaint is less about blame, and more about outcomes. That focus is likely to shape how home insurance claims are discussed for some time to come.
