The Insurance Council of Australia (ICA) has closed public consultation on its redrafted General Insurance Code of Practice, receiving 28 submissions from consumer representatives, industry participants, and other interested parties. The ICA announced July 24, 2026, that the review has moved into an analysis phase, with submissions to be published subject to confidentiality requirements. The figure represents a slight increase from the 22 submissions received during the initial 2023-24 independent code review consultation – a signal of a broader range of stakeholders engaging with the conduct standards that govern Australian general insurance.
The General Insurance Code of Practice has been in place since 1994 and is subject to an independent review every three years. The current redraft reflects recommendations from the 2023-24 Independent Code Review and the ICA’s Industry Action Plan, released in March 2025 following the Parliamentary Flood Inquiry into insurers’ responses to the 2022 floods. ICA chief executive Andrew Hall has framed the exercise as both a compliance and a trust imperative. “For the first time, insurers’ key commitments under the Code will be legally enforceable, claims left undecided after 12 months will be automatically accepted, and new vulnerability protections provide greater support for customers who need it most,” Hall said. He added that the rewrite is being undertaken against a backdrop of evolving climate risk, regulatory change, and shifting consumer expectations.
The timeline has already slipped once. The ICA confirmed that lodgement with the Australian Securities and Investments Commission (ASIC) for approval was pushed back to the second half of 2026, behind the timeline originally forecast in May 2025, when the ICA had expected to lodge the code with ASIC for approval by mid-2026. Hall has indicated 2028 as the expected effective start date, allowing insurers time to adapt and reissue their product disclosure statements.
The draft’s central change is that key insurer obligations would become legally enforceable as part of consumer contracts, subject to ASIC approval. Other proposed changes include the automatic acceptance of home and motor claims left unresolved after 12 months, a new circumstances-based definition of vulnerability with an accompanying Extra Care framework, and broadened family violence protections covering financial abuse and coercion.
The 12-month automatic acceptance provision responds directly to documented systemic shortfalls. The industry reported 5,714,161 lodged claims across 41,595,965 policies in 2024-25. Against that volume, the General Insurance Code Governance Committee’s (GICGC) Annual Industry Data and Compliance Report for 2024-25 recorded 70,325 code breaches – a 20.5% rise on the 58,385 logged the year prior, with claims-related failures making up 59% of that total, or 41,140 breaches. The obligation to advise customers of a claims decision within 10 business days of receiving all relevant information produced 11,180 breaches in the period alone.
More than half of Australian general insurers that breached key claims-handling timeframes in 2024-25 could not say by how many days they had kept customers waiting – a data gap the GICGC chair Veronique Ingram described as more consistent with structural failure than individual fault. “Good data helps insurers see where they are failing to meet their commitments and take action before they become widespread. Without that visibility, it is harder to address the root causes of issues that affect customers’ experiences,” Ingram said.
Complaints handling adds a further layer of regulatory exposure. ASIC’s REP 802, published in December 2024 following a review of 11 general insurers representing approximately 86% of the market by premium, found that insurers failed to identify one in six customer complaints. Insurers identified only 85 systemic issues from over 1.4 million complaints, while nearly 50% of insurers did not identify a single systemic issue.
ASIC has welcomed signals from the ICA of its intention to seek approval for the updated code, noting that only the Banking Code of Practice currently holds ASIC approval. Approval under the Corporations Act would shift the code from a voluntary industry framework to one where obligations are directly arguable through AFCA or the courts. ASIC Commissioner Alan Kirkland addressed the stakes at the ICA’s Annual Conference in October 2025: “The development of a new General Insurance Code of Practice that will be enforceable by contract is an important step towards rebuilding trust. However, unless the provisions themselves improve overall levels of consumer protection, it will be a step backwards.”
The 28 submissions are unlikely to be uniform in their support. Australian Consumers Insurance Lobby (ACIL) chair Tyrone Shandiman said in a statement published during the consultation period: “The Insurance Council has once again prioritised commercial interests ahead of professional standards. After years of inquiries, reviews, and public criticism, the industry was handed a clear roadmap for reform. Instead, it has chosen to water down existing protections and leave many of the most significant recommendations unaddressed. This is no longer a drafting issue. It is a governance failure.” Shandiman added that while ACIL supports contractual enforceability in principle, enforceability alone has limited value if the underlying standards are inadequate: “A weak code that is contractually enforceable is still a weak code.”
The ICA has characterised the redraft as developed through extensive pre-consultation with consumer advocates, regulators, and the GICGC – a process it says distinguishes this iteration from prior versions. In 2024-25, the GICGC oversaw $2.9 million in remediation payments to 13,528 consumers affected by breaches and imposed sanctions on two insurers for serious non-compliance – figures that underline the commercial and reputational stakes of what the new code will require.
The ICA has not confirmed a date for completing its analysis of submissions or for lodging the final code with ASIC. The current code remains in effect in the interim.
