Briefing: What an unexpected pet insurance claim can reveal about Consumer Duty in practice

Christmas Day 2025 was going well until my dog, Pepper, ate a mince pie.

She is fine now – thankfully – but what followed this edible incident has stuck with me far longer than the accident itself.

This included an out of hours emergency vet visit, an injection, a hefty surcharge for an appointment outside normal operating hours and then – days later – an additional admin fee for paperwork that was needed to support the insurance claim.

That final admin charge was not covered by my pet insurance policy.

None of this is unusual in isolation. Vets charge out of hours fees. Insurance policies have exclusions. Admin fees exist. But taken together – and crucially, experienced at a moment of stress, urgency and emotional vulnerability – this amalgamation raises an uncomfortable question for the UK general insurance (UKGI) industry. Are we technically complying with Consumer Duty regulation if we are undermining the spirit of these rules in practice?

The issue here is not the existence of fees. It is more when and how customers encounter them. In emergencies, pet owners have little choice, for example. There is no shopping around, no time to interrogate terms, no meaningful ability to opt out.

Decisions are made quickly, while under pressure, with the assumption that insurance will smooth the process rather than add friction.

Yet in practice, additional costs can emerge after the fact, sitting outside purchased cover but squarely within the lived experience of making a claim. From a customer perspective, there is no neat distinction between insurer, vet, claims administrator or third party provider.

There is just one joined up journey – and it is that journey that Consumer Duty is meant to protect.

This is where the tension lies. Insurers are rightly quick to point out that they do not set veterinary pricing, nor can they control admin fees charged by third parties.

That is true. But Consumer Duty was never meant to be about narrow contractual responsibility. It is explicitly outcomes focused. It asks whether foreseeable harm has been anticipated and mitigated, not whether the small print technically allows something to happen.

Customer confusion

Admin fees, paperwork charges and opaque out of hours costs may sit outside insurance policy wordings, but they do not sit outside customer perception.

If someone believes they have done the right thing – taken out cover, paid premiums, followed the claims process – and still find themselves surprised by additional charges at the point of need, trust is eroded quickly.

What makes this situation more pressing is that claims are already the pressure point for pet insurance. Complaints data for 2025’s third quarter, reviewed by Insurance DataLab, shows rising escalation to the Financial Ombudsman Service (FOS), with the claims process at the centre of most disputes.

That suggests a system under strain, where small frictions can easily tip into dissatisfaction.

My own complaint is now with the FOS, with a separate one raised with the Royal College of Veterinary Surgeons. I do not yet know how they will be resolved.

But that is almost beside the point.

The bigger question is whether UKGI is designing insurance journeys around how people actually experience them – particularly in emergencies – or whether we are relying too heavily on technical compliance to carry the weight of customer outcomes.

Consumer Duty was supposed to shift that mindset. The risk now is that, without greater attention to the gaps between parties, we comply with the letter of the rules while quietly undermining what they were meant to achieve.