The Australian and New Zealand Institute of Insurance and Finance (ANZIIF) has opened registrations for a short course on New Zealand’s Contracts of Insurance Act 2024 (CoIA), ahead of the legislation’s November 2027 commencement date. The course targets professionals in underwriting, claims, sales, service, and intermediary roles across life and general insurance.
The CoIA overhauls the legislative framework governing insurance contracts in New Zealand, with changes spanning the full policy lifecycle – product design, distribution, claims handling, disclosure, and customer outcomes are all affected. On disclosure, the Act shifts away from requirements that have been described as broad and ambiguous. Rather than being held to an expansive disclosure standard, consumers will be required to take reasonable care not to make a misrepresentation. The FMA has described this as a move toward clearer, more practical expectations for consumers at the point of entering into a contract.
Where a consumer falls short of that standard, the Act requires insurers to respond in proportion to the breach. The FMA's letter to insurers described this as ensuring responses are fair and appropriately aligned with the nature and impact of the non-disclosure or misrepresentation, rather than defaulting to the harshest available outcome. Taken together, the FMA characterised the reforms as an effort to rebalance the relationship between insurers and policyholders – improving the fairness of contract terms and insurer conduct while preserving the ability of individuals and businesses to manage risk.
ANZIIF’s short course is built around the practical application of the CoIA changes for professionals working across technical and customer-facing functions. It addresses the intent behind the reforms; the adjustments required to internal processes and decision-making; steps that teams across underwriting, claims, intermediaries, and service functions should be taking during the lead-up period; and how to identify policy wording, procedures, and documentation that will need to be reviewed before November 2027.
ANZIIF CEO Katrina Shanks said the changes would be felt across a range of roles. “These reforms will change how New Zealand insurance professionals make decisions, communicate with customers, and apply regulatory obligations in day-to-day practice. Our role is to help insurance professionals build the confidence and practical capability to adapt early, strengthen customer outcomes, and stay ahead of changing industry expectations,” Shanks said.
Concurrent with the course opening for registrations, the FMA issued an open letter to insurers detailing what the regulator expects from the industry during the implementation period leading up to November 2027. Clare Bolingford, the FMA’s executive director of licensing and conduct supervision, wrote that the CoIA sits alongside, but separate from, existing conduct regulation. “CoIA is distinct from, but complementary to, other conduct and market regulation. It focuses primarily on the fairness of contract terms and on the conduct of insurers in their direct dealings with individual policyholders, including how underwriting questions are asked, how disclosure is assessed, and how remedies are applied,” Bolingford wrote.
The letter identified several areas where the FMA expects work to already be underway: gap and impact assessments, an understanding of how current practices measure against CoIA requirements, identification of where changes or redesign are needed, and the integration of CoIA considerations into governance, risk management, and assurance frameworks. On the question of insurers holding off until final regulations are published, Bolingford was direct. “We do not consider it appropriate to delay implementation planning until regulations are finalised. The regulations represent a small component of the reforms and consultation undertaken to date provides a sufficient basis for insurers to progress extensive implementation work. Delaying preparation increases the risk of compressed timeframes, incomplete implementation, and avoidable compliance and conduct risks,” Bolingford said.
The letter made clear that the FMA’s supervisory and enforcement tools under the Financial Markets Conduct Act will be applied from the point of commencement. The regulator said it would be assessing whether CoIA requirements have been embedded across product design, sales, underwriting, policy administration, and claims handling, and whether implementation has been treated as a substantive reform rather than a narrow compliance task. “Insurers should ensure that CoIA implementation is not approached in isolation and should align with broader fair conduct obligations so that consumers are treated fairly throughout the insurance lifecycle,” Bolingford wrote.
The letter also addressed how insurers communicate the changes to their customers. The FMA expects insurers to assess whether policyholders need advance notice of changes to their obligations or their cover and to ensure that any such communication gives consumers a reasonable opportunity to understand and respond to those changes. “Communication should be timely, clear, concise, and effective, particularly where changes may impact consumer understanding or outcomes,” Bolingford wrote. The FMA said it would continue to engage with insurers and industry bodies as implementation work develops, and asked that insurers raise practical challenges or areas of uncertainty early rather than waiting until commencement approaches.
