The Australian Financial Complaints Authority (AFCA) has released a guide outlining how insurers, complainants, and their representatives should structure submissions when hail damage claims reach the external dispute resolution (EDR) stage. The document, published June 3, 2026, establishes page limits, evidence requirements, and formatting expectations for all parties involved in the process. The move comes as industry data points to a significant rise in weather-related claims across Australia, putting pressure on dispute resolution pipelines and raising the stakes for how complaints are managed once they escalate beyond the insurer level.
A central purpose of the guide is to narrow the scope of what parties submit. AFCA has observed that submissions in hail damage complaints often include material that does not bear directly on the issues in dispute, which slows down the resolution process. The guide is intended to address that by giving parties a clearer picture of what AFCA actually needs from them. Parties are expected to keep their case summaries to two pages. Submissions addressing individual issues in dispute are also capped at two pages per issue. Should a complaint advance to determination after a preliminary assessment, each party is permitted a final submission of no more than five pages, limited to reasons for disagreeing with the preliminary assessment and any new relevant information not previously provided. AFCA noted it may decline to consider material that falls outside these parameters and said it would inform parties when that decision is made.
The guide breaks down evidentiary expectations according to the type of dispute. In roof damage cases where a complainant is seeking full replacement rather than repair, the submission needs to include assessor reports, photographs, and a reasoned explanation of why repair or partial replacement would not adequately address the damage. Supporting documents such as quotes or a scope of works should also be attached.
Solar panel claims carry their own set of requirements. Because damage to panels can be difficult to attribute to a specific event, AFCA expects complainants to build a more layered evidentiary case. That includes dated photographs taken after the storm, weather data confirming hail fell at the property on the relevant date, technical details about the solar system, and performance records showing a measurable drop in output following the event.
The guide also addresses electroluminescence (EL) testing, a method used to detect cell-level damage in solar panels that would not appear in standard photos. AFCA’s position is that such testing can support a claim but is not sufficient on its own to establish that hail caused the damage. It is to be used alongside other evidence, including site inspection findings and weather data, rather than as a standalone proof of causation.
On the question of professional costs, the guide states that AFCA has the discretion to require an insurer to contribute to costs a complainant incurred during the dispute process, though it stops short of guaranteeing such an outcome. Any award of this nature is ordinarily capped at $5,000 per complaint, regardless of the number of issues raised, and is assessed with reference to the complexity of the matter and whether the costs were reasonably necessary for the complainant to understand or establish their claim.
The guide also flags the use of artificial intelligence in preparing submissions. Parties who use generative AI tools to draft material remain fully responsible for what they submit, including the accuracy of any facts, figures, or citations included. AFCA expects all AI-assisted content to be thoroughly reviewed before lodgement. Separately, the authority noted that where a complainant has appointed a paid representative, settlement offers must be passed on to the complainant promptly, and representatives are expected to give informed advice on the merits of any offer made by the insurer.
The guide arrives at a time when hail and storm-related claims are running at historically high levels. According to figures released by the Insurance Council of Australia (ICA) in April 2026, insured losses from extreme weather reached $4.8 billion in 2025, up from $585 million the year prior. Insurers processed 294,000 claims from declared extreme weather events across the year, with the average cost per claim rising to $16,471.
The November 2025 storm and hail event across Queensland and New South Wales was the single costliest event of the year, producing nearly 93,000 claims and $1.78 billion in insured losses. A separate spring storm event across South East Queensland and Northern New South Wales added a further $900 million across 41,200 claims. That volume of activity means more disputes are likely to work their way through to the EDR stage, making AFCA’s submission framework directly relevant to how insurers and their legal or claims teams approach the complaints process in the months ahead.
