The General Insurance Code Governance Committee (CGC) has detailed its program of remediation audits, enforcement activity and industry guidance in its 2024-25 Annual Report, setting out how it is applying the General Insurance Code of Practice across Australia’s market.
Over the year, the committee reported that $2.9 million was returned to 13,528 customers through insurer remediation programs linked to code breaches. It initiated 14 remediation audits and imposed sanctions on two insurers for systemic issues in claims and complaints handling. CGC chair Veronique Ingram said the committee’s work is directed at ensuring issues identified by insurers lead to changes in how they operate. “When insurers identify and correct issues, customers experience fairer outcomes. It also leads insurers to strengthen their systems for the future. These outcomes show the impact that effective oversight can have for customers,” Ingram said.
In its report, the CGC said its strategy continues to rely on insurers self‑identifying significant breaches of the General Insurance Code of Practice, supported by root cause analysis and remediation plans. The committee then directs its own resources to higher‑risk cases and cross‑industry themes.
Insurers reported 114 significant breaches to the CGC in 2024-25. According to the committee, 78 of those matters were supported by analysis of underlying causes and defined remediation steps. Those cases were closed after the CGC assessed the likelihood of recurrence as low. Another 35 significant breaches were linked to remediation programs but were scheduled for post‑remediation audits, reflecting potential for repeat issues or uncertainty about how effectively changes would operate in practice. The committee noted that matters depending on manual controls, such as staff training or revised reporting, were more likely to be followed up.
Remediation audits are now a regular component of the CGC’s oversight. In 2024-25, the committee commenced 14 audits and finalised 10. In the completed matters, the CGC recorded that remediation was implemented as agreed and that reported breach numbers had fallen. Four audits remain open while the committee assesses whether control changes are preventing further incidents.
The CGC escalated two matters to formal sanctions during the year, describing them as serious or systemic non‑compliance with the code. In one case, an unnamed insurer was sanctioned after the committee identified multiple shortcomings in claim handling. These included inadequate repair work, failure to identify and address mould damage, and delays associated with disputes about the scope of repair works. Thirty‑five customers were affected.
As part of the sanction, the insurer was required to make a $100,000 Community Benefit Payment to a fund administered by the Australian Communities Foundation (ACF). The CGC stated that the insurer had conducted broad reviews, recognised the systemic nature of the issues, and reported and remediated affected policyholders on its own initiative. On that basis, the committee published a de‑identified case study rather than naming the insurer.
A second sanction was issued to AIG Australia Ltd (AIGAL) in relation to complaints and claims‑related communications. The CGC found that AIGAL repeatedly failed to give customers timely updates and decisions on their complaints and did not consistently advise them of their right to escalate disputes to the Australian Financial Complaints Authority (AFCA). More than 700 customers were affected. Sanctions required AIGAL to audit its compliance with relevant code obligations, make a $30,000 Community Benefit Payment and publicly disclose the facts of the significant breach. The CGC said it continues to monitor both sanctioned insurers’ responses.
The committee received 96 allegations of potential code breaches in 2024-25, compared with 153 the previous year. Allegations came from customers, consumer advocates, representatives, AFCA, and other third parties. The most common issues raised related to general claims management, treatment of customers experiencing vulnerability and delays in claims decisions.
The CGC completed 10 investigations during the period, covering six insurers. These inquiries examined support for vulnerable customers, complaints processes, access to information, debt collection practices, and broader obligations to act honestly, efficiently, fairly, transparently, and in a timely manner. Across those investigations, the committee identified 36 breaches of the code. Remediation plans included compensation for non‑financial loss, apology letters, staff training, changes to policy disclosures, and adjustments to internal processes and procedures.
The report restated the CGC’s reliance on self‑reported breach data, which is consolidated in its Industry Data and Compliance Report. The 2023-24 report showed a decline in overall breach numbers and increased reporting of qualitative breaches, including those involving vulnerable customers. Over the same period, complaints rose by 18%, particularly in relation to motor cover and premium increases. The committee said insurers should review the timeliness and efficiency of their complaints handling in light of these trends.
The CGC also described follow‑up work on its thematic inquiry into insurers’ use of external experts in claims, which arose from concerns about decisions based on wear‑and‑tear and maintenance exclusions. Six insurers from the initial inquiry, plus two additional insurers, were reviewed in 2024-25. According to the committee, insurers have reported changes to how expert reports are commissioned and used, to training programs for claims staff, and to internal accountability for decisions relying on external advice. Many of these initiatives are still being implemented and will be reviewed over the coming year.
As part of its monitoring program, the CGC examined the relevance of questions used in online motor insurance applications. The review covered 13 insurers and 58 brands and assessed whether information requested at application stage was necessary for underwriting, in line with code requirements. The committee identified questions where the link to underwriting decisions was not clear and sought explanations from participating insurers. It concluded that insurers could increase transparency by explaining why particular data points are collected and how they affect decisions to offer or decline cover. The CGC’s report includes recommendations that it says are intended to adjust assessment practices, customer understanding, and the transparency of underwriting decisions. A follow‑up assessment is planned for 2025-26, and the committee has indicated it may consider further enforcement if it does not see sufficient progress.
During 2024-25, the CGC issued updated guidance and compliance reminders on vulnerability, acceptance of standard authority forms, and oversight of third‑party service providers. In response to concerns from consumer groups about rejected or ignored authority forms, the committee reviewed insurer practices and found that while acceptance of standard forms has increased, inconsistencies remain. It has recommended more consistent approaches to recognising third‑party authorities, particularly for customers working with financial counsellors or other advocates, and said it will continue to monitor developments in this area.
Additional guidance clarified that code obligations extend to services delivered by third‑party providers on an insurer’s behalf and set out expectations for how claim decisions are communicated to customers to help reduce disputes. “Our inquiries and guidance give insurers the tools and clarity they need to strengthen their systems, communication, and decision-making, supporting better outcomes for customers,” Ingram said.
For 2025-26, the CGC has identified three monitoring priorities: aspects of complaints handling, pricing transparency in relation to premium increases, and the identification and treatment of customers experiencing vulnerability. These priorities draw on breach data and recommendations from the Independent Code Review and inquiries into insurers’ responses to flood events.
The committee also pointed to forthcoming changes to the General Insurance Code of Practice. The Insurance Council of Australia (ICA) intends to make the code enforceable by contract and to seek Australian Securities and Investments Commission (ASIC) approval. Although implementation of the new code has been deferred to July 1, 2027, the CGC expects the next year to involve work on consultation, feedback on draft provisions, and updated guidance materials. The committee said it will oversee transition planning and monitor how insurers adjust practices to meet revised expectations on claims handling, support for vulnerable customers, and financial hardship assistance.
