Financial Ombudsman Service decision

Intact Insurance UK Limited · DRN-6138725

Insurance Pricing & RenewalComplaint not upheld
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The verbatim text of this Financial Ombudsman Service decision. Sourced directly from the FOS published decisions register. Consumer names are reduced to initials by FOS at point of publication. Not an AI summary, not a paraphrase — every word below is the original decision.

Full decision

The complaint Mr E and Miss K complain about the price quoted by Intact Insurance UK Limited (“Intact”) to renew their home insurance policy. Mr E has acted as the main representative during the complaint process. So, for ease of reference, I will refer to any actions taken, or comments made, by either Mr E or Miss K as “Mr E” throughout the decision. What happened Mr E received a quote to renew his policy which he says was significantly higher than what he’d paid the previous year. Mr E complained about the renewal prices Intact had charged since 2022 and said the price had increased significantly despite there being no changes to his property, claims history or his risk profile. Intact responded and explained the prices they’d charged were correct. They said they take many factors into account, such as inflation and changes in external risk, when rating and pricing a policy. Intact explained the price was calculated by looking at factors such as Mr E’s property details, the postcode and claims history. They said, despite Mr E having a good claims history and details about his property hadn’t changed, Intact had experienced an increase in claim costs, which is then reflected in the premiums they charge. They acknowledged Mr E would like a more detailed explanation for the price increase but explained this information was commercially sensitive. Our investigator looked into things for Mr E. She thought Intact hadn’t treated Mr E unfairly in relation to the pricing. Mr E disagreed so the matter has come to me for a decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so, I’ve decided not to uphold the complaint. I understand Mr E will be disappointed by this but I’ll explain why I have made this decision. The role of this service when looking at complaints about insurance pricing isn’t to tell a business what they should charge or to determine a price for the insurance they offer. This is a commercial judgement and for them to decide. But we can look to see whether we agree a consumer has been treated fairly – so is there anything which demonstrates they’ve been treated differently or less favourably. If we think someone has been treated unfairly, we can set out what we think is right to address this unfairness. I can see Mr E paid £574.99 for his policy in 2022, followed by £686.04 in 2023 – which represents an increase of 19%. The price for the 2024 policy was £1,029.06 – an increase of 50% from the previous year. Mr E was then quoted £1,210.86 for his policy in 2025. This represents an 18% increase from the previous year, but an increase of just over 110% compared to the price Mr E paid in 2022. So, I understand why Mr E is concerned about the

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price increase. Intact have provided me with confidential business sensitive information to explain how Mr E’s prices were calculated. I’m afraid I can’t share this with Mr E because it’s commercially sensitive, but I’ve checked it carefully. And I’m satisfied the prices Mr E was quoted have been calculated correctly and fairly and I’ve seen no evidence that other Intact customers in Mr E’s position will have been charged a lower premium. As mentioned above, I can’t provide specific detail about Intact’s risk model, but I’ve seen information which shows the risk assessment carried out by Intact, and this relates to the presentation of risk. I can’t say there are reference to any factors here which are unusual or uncommon for insurers to use when assessing risk for a home insurance policy. One of the main factors which has contributed to Mr E’s policy price increases over the last few years, relates to a general price increase. It’s been widely publicised over the last few years that the price of home insurance has increased due to claims inflation and insurers facing rising costs in settling claims – and this includes the cost of labour and building parts and materials. This again isn’t unusual or uncommon, so I can’t say Intact have acted unfairly here. This forms part of Intact’s pricing model so it applies to all policies. I think that’s important here as it demonstrates the pricing model used to calculate Mr E’s premium was no different to what was used for any other customer in the same circumstances. I do acknowledge Mr E’s concern about the renewal quote in 2025 when compared to the price he’d paid in 2022. I also acknowledge Mr E says he decided to take out a new policy with a different provider in 2025, and this was for a price significantly lower than what Intact had quoted. Mr E has also provided details of other quotes he obtained – which again show prices lower than what Intact had quoted. I acknowledge Mr E’s concern in this respect, but it’s for a business to decide what risks they’re prepared to cover and how much weight to attach to those risks - different insurers will apply different factors. That’s not to say an insurer offering a higher premium has made an error compared to an insurer offering a cheaper premium – but rather, it reflects the different approach they’ve decided to take to risk. This similarly applies to rating factors and loadings. It’s for an insurer to decide what rating factors and loadings to apply to a policy. This then determines the price at which an insurer is prepared to offer cover. Mr E says there’s been no change to his property, claims history or his risk profile, so he believes it’s unfair the price should increase by the amount it has over the last few years. But, even though, from a customer’s perspective, all factors may still be the same from the year before, insurers will regularly refresh their pricing model based on wider claims experience and to predict future underwriting costs. That’s what’s happened here, so I can’t say Intact have acted unfairly. In addition to this, I’ve seen that Intact did remind Mr E that he could shop around to see if he could get a better price. As there had been at least four renewals, then Section 6.5 of the Insurance Conduct of Business Sourcebook (“ICOBS”) requires a business to provide specific wording about the benefits of shopping around. So, as well as treating Mr E fairly, I think Intact also acted in line with requirements set out under ICOBS. I can see Mr E says, while searching the market for quotes from other providers, he obtained a new business quote from Intact for £637.98 – which is significantly lower than the renewal quote he received in 2025. Mr E says this, together with the total percentage price difference between the 2022 and 2025 premiums, goes against the fair pricing rules. I have therefore considered the Financial Conduct Authority (“FCA”) fair pricing rules. The rules for general insurance pricing were introduced by the FCA in January 2022. They apply to motor and buildings insurance only and insurers need to make sure they comply with

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these rules when offering renewals. The rules aren’t retrospective and only apply to renewals generated from 1 January 2022. The rules were put in place to remove the risk of existing customers paying more than new customers. It places an obligation on insurers to make sure they charge renewing customers the same as new customers. The FCA refers to this as the equivalent new business price (“ENBP”). The ENBP needs to be reflective of the new business price the day the renewal invite is generated. It is accepted the view of risk can change and the rules don’t mean all insurers need to charge the same price and the FCA accepts that policies bought through different brands will likely offer similar cover at different prices. It also understands that different sales channels for the same brand might result in different prices and it accepts this is fair. The new pricing rules were in place when Mr E was offered his renewal in 2025, so Intact did need to follow these at the time. And, having carefully reviewed the information provided by Intact, I’m satisfied they haven’t made a mistake or failed to offer Mr E an ENBP. I say this for a number of reasons. Firstly, Intact say they don’t have any record of Mr E generating a new business quote for the specific product he had for a price of £637.98. They’ve explained the quote might well have been for a similar product offered by the same broker, but with a different underwriter. Secondly, even if it was the same product offered by Intact and I can see Mr E has provided evidence of a quote he obtained for £833.51, as mentioned above, the ENBP needs to be reflective of the new business price the day the renewal invite is generated. But in this case, the new business quote obtained by Mr E for £833.51 was generated around seven months after the renewal quote was generated. So, I don’t think it’s unreasonable to expect at least some rating factors and Intact’s view of risk to have changed between this period. Finally, and as mentioned above, the FCA understands that different sales channels for the same brand might result in different prices and it accepts this is fair. In this case, a different sales channel was used to generate the new business quote compared with the renewal quote. So, I haven’t seen any evidence that Intact acted in a manner which wasn’t consistent with the fair pricing rules. I do appreciate Mr E wanted Intact to provide more detail around what specific factors led to the renewal quote. Pricing is an area where the information which sits behind an insurer’s explanation will often be commercially sensitive. So, I don’t think Intact have acted unreasonably in not providing Mr E with details of the specific ratings and loadings used to calculate the price. I understand why Mr E has complained, and I hope he feels reassured that I’ve checked the pricing information from Intact. But I can’t say they’ve made a mistake or treated Mr E unfairly. I wish to reassure Mr E I’ve read and considered everything he has sent in, but if I haven’t mentioned a particular point or piece of evidence, it isn’t because I haven’t seen it or thought about it. It’s just that I don’t feel I need to reference it to explain my decision. This isn’t intended as a discourtesy and is a reflection of the informal nature of our service. My final decision For the reasons I have given, it is my final decision that the complaint is not upheld. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr E and Miss K to accept or reject my decision before 24 April 2026. Paviter Dhaddy Ombudsman

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