Firms have until November to implement these rules

The FCA has introduced rules for the travel insurance industry to ensure those with pre-existing medical conditions (PEMCs) are better protected.

Currently, consumers with PEMCs face difficulties such as not being able to travel, being underinsured, travelling without any insurance and potentially being liable for hefty medical bills, and being unable to navigate the market.

The FCA hopes its new rules will increase consumer confidence in the travel insurance industry. 

The rules will require those offering travel insurance to:

  • Signpost certain consumers with PEMCs to a directory of specialist providers.
  • Introduce guidance that firms selling travel insurance policies that exclude PEMCs should tell consumers whether and how these PEMC exclusions can be removed.
  • Introduce guidance for firms reminding them to assess the risk from medical conditions and calculate medical condition premiums using reliable information that is relevant to assessing this risk. This will help make sure that consumers are quoted a fair premium which properly covers their circumstances.

The FCA said the changes would be applicable to all firms that offer retail travel insurance, including insurers, Lloyd’s managing agents, intermediaries and appointed representatives.

It will also apply to banks offering packaged bank accounts which include travel insurance, insurance industry trade associations, as well as consumers with PEMCs.

One concession it did make from the original proposals was to only require signposting where a customer has a PEMC loading of £100 or more.

It said this was changed ”in light of the feedback received to the overall consultation”.

”We believe this more effectively targets the consumers who are likely to benefit from signposting. 

It said the change means that ”some, but not all, consumers with PEMCs that result in an additional loading will be signposted to the directory”.

it added that the change would lead to a “marginal reduction” in communication costs, as not all customers with PEMCs would need to be signposted.

The ABI’s director of regulation Hugh Savill said that ”While we welcome the FCA’s changes to strengthen the current signposting measures, the £100 premium loading trigger must be carefully and thoroughly worked through to ensure that it delivers real customer benefits and makes the buying process as smooth as possible.

“The vast majority of consumers can obtain travel insurance, including those with pre-existing medical conditions,” Savill added.


The FCA said that currently some consumers with PEMCs struggle to find affordable cover, with some declined insurance or offered products that exclude their condition or priced exorbitantly.

The FCA set up a consultation with the industry last summer on how to better signpost consumers to suitable travel insurance firms. The consultation also looked at how those with PEMCs could be treated better.

It received 37 responses from across the sector which has led to the latest rules.

These rules must be implemented by 5 November 2020, the FCA said, with firms also required to include details of the directory on their websites within 30 days of the directory being made live (expected by summer this year).

Reviews of whether and how the changes are being implemented will be undertaken by the regulator every 12-18 months, it added.

Application details for the directory will be published later this month, the FCA said.

Biba reaction

Commenting o the new rules, Biba executive director Graeme Trudgill said the trade body was ”highly supportive of signposting consumers to a specialist insurance provider.

”Helping people that have pre-existing medical conditions to more easily access travel insurance is a key commitment in our 2020 Manifesto.

”We are pleased that the new FCA rule(s) relating to access allows the flexibility for firms to meet the signposting requirement by choosing to signpost to an organisation (other than MAPS) hosting a directory of suitable specialists, providing that they meet the FCA criteria and are listed on the FCA website as a medical cover firm directory.

”BIBA has been in discussions with the FCA about the development of our successful Find-Insurance Services, and we are ready to make the changes required and will be looking to apply to be listed as a medical cover firm directory.

BIBA will now be reading the policy statement in detail to progress our involvement.