AuditSail
FCA80% of GAP market paused sales · 2024
INDUSTRY · INSURANCE & PROTECTION

Your AR just quoted "unbeatable cover." Can you prove it?

Consumer Duty, ICOBS and the GI pricing rules create a triple bind: your appointed representatives' marketing has to be clear, fair and not misleading - and the product has to offer fair value. AuditSail checks your ARs' ads, call scripts and call recordings against your rules.

  • FCA
  • ICOBS
  • Consumer Duty
  • PS21/5
  • ASA
EXAMPLE
Image ad · AR 1Flagged
AR 1 · SponsoredPet insurance

Unbeatable cover.

UsOther insurers
Monthly price£4.99£9.99
Vet fees cover£4,000£2,000
Get a quote →Key exclusions: not shown
!
FailHigh

"Unbeatable cover" is an absolute claim, with nothing shown to back it.

FCA · ICOBS 2.2 · clear, fair, not misleading+2 more findings

LINES COVERED

MotorHomeTravelPetGAP coverLifeIncome protectionCritical illnessHealth insuranceCommercial GI
THE FAIR-VALUE PROBLEM

Three frameworks. One ad campaign.

ICOBS says be clear, fair and not misleading. Consumer Duty says prove the outcome was good. GI pricing rules say no "loyalty penalty." Your comparison-site listing has to clear all three at the moment of quote - and as the principal, you're responsible for what your appointed representatives publish.

Insurers covering 80% of the GAP market paused sales after the FCA raised fair value concerns.

FCA PRESS RELEASE · FEBRUARY 2024
THE DISTRIBUTION CHAINEXAMPLE
  1. Insurer / MGA
  2. Principal broker
  3. Appointed RepresentativeFlagged
  4. Comparison site / PCW
  5. Affiliate / lead-gen

Five tiers · one audit trail · 1 flagged

OUTCOMES

Every AR. Every ad. Every call.

01

ICOBS 2.2 · ad-level checks

"Clear, fair and not misleading" checked before the asset ships - absolute claims, comparative pricing, exclusions disclosure.

02

Principal → AR oversight

Under SUP 12, a principal is responsible for its appointed representatives. See the ads, call scripts and call recordings each AR submits, and how each was graded.

03

Consumer Duty rule pack included

Check assets against the included Consumer Duty rule pack alongside your own rules for each product. Review and sign-off stay with your team.

Image ad · AR 1EXAMPLE
  • No absolute claimsFCA · ICOBS 2.2HighFail
  • Key exclusions disclosedFCA · ICOBS 2.2MediumFail
  • Basis of price comparison shownFCA · ICOBS 2.2Inconclusive
  • Price and cover explained clearlyConsumer DutyPass
Score58/100 · pass mark 80
Sign-offRejected · Reviewer 1
THE PRESSURE ON GI & PROTECTION

PS21/5 · Consumer Duty · GAP intervention.

6%Of GAP premiums paid out in claims · FCA, Feb 2024
19,766Promotions amended or withdrawn after FCA intervention · 2024

Sources: FCA, GAP insurers agree to suspend sales, February 2024; FCA, Financial promotions data 2024

RELATED INDUSTRIES & SOLUTIONS

Same playbook. Different sector.

LAST WORD

See what's running in your name. Before a regulator does.

30 minutes with our team. We'll show you AuditSail checking assets like yours and answer your questions.

Companies House registered
Data stored in the UK
England & Wales rules