Burnham's subscription clampdown skips insurance - but your cancellation process is still an issue

Insurance is exempt from the PM's new subscription rules, but the FCA already requires renewal cancellation to be as easy as buying - here's the specific check to run this week

Burnham's subscription clampdown skips insurance - but your cancellation process is still an issue

Insurance News

By Mark Rosanes

Prime Minister Andy Burnham has pledged to crack down on subscription traps and misleading retail discounts. FCA-regulated insurance sits outside the new rules. The announcement nonetheless intensifies pressure on insurers and brokers whose add-on and auto-renewal practices remain under active regulatory scrutiny.

Burnham announced on August 9 that the government would launch a consultation on banning deceptive pricing tactics, including fake claims about previous prices, invented discounts, and misleading recommended retail prices. The proposals would bring those practices under the Digital Markets, Competition and Consumers Act 2024 (DMCCA).

New subscription rules under the DMCCA are set to take effect in January 2027. Businesses must provide clearer upfront information, regular renewal reminders, and a straightforward exit path. A 14-day cooling-off period will apply when a trial ends or a long-term contract of 12 months or more auto-renews.

Insurance products regulated by the Financial Conduct Authority (FCA) are formally exempt from the DMCCA subscription regime. But the political momentum behind Burnham's announcement, combined with existing FCA obligations, means brokers and insurers cannot treat that exemption as a reason to stand still.

Add-on rules under scrutiny

Personal lines insurers routinely bundle ancillary products such as legal expenses, breakdown cover and key cover alongside motor and home policies, often on an opt-out or auto-renewal basis. The FCA banned opt-out selling of add-ons across financial services in April 2016, requiring consumers to actively elect to purchase any additional product.

The regulator updated ICOBS 6A.6 as recently as June 2026. Firms are now obliged to offer cancellation methods for auto-renewal features that are at least as accessible as those available for new purchases. The rules support the Consumer Duty requirement to avoid foreseeable harm and remove unreasonable barriers to switching.

That specific standard, cancellation as easy as purchase, is the one concrete thing worth checking this week rather than waiting for a compliance audit to flag it. If a customer can buy an add-on in two clicks online but has to phone a call centre during business hours to cancel it, that gap is already a live ICOBS 6A.6 breach, not a future risk. Brokers running their own direct digital journeys, or reviewing an insurer partner's renewal flow before recommending it, should walk through both paths themselves and time them side by side.

PROD 4 and the distributor gap

Beyond add-ons, the FCA's 2024 product governance thematic review, TR24/2, found widespread shortcomings in how insurers and intermediaries manage product oversight. The regulator assessed 28 manufacturers and 39 distributors across 10 general insurance and pure protection products. The FCA said it was "disappointed to see many firms failing to fully meet their regulatory obligations under PROD 4," with identified gaps covering fair value assessments, target market definitions and distribution oversight.

Brokers and aggregators that use multi-year policy locks or pre-selected add-on bundles face particular scrutiny under that framework. In 2026, the FCA is actively testing firms' pricing, product governance, and customer treatment approaches. Firms identified as outliers are expected to justify that position with evidence.

Burnham's broader consumer push

The Prime Minister, who took office on July 20, has moved quickly on household cost-of-living measures. He has removed a tax from domestic electricity bills, capped bus fares, and lowered business rates for pubs, clubs and live music venues, according to a Reuters report.

The British Retail Consortium, which represents major retailers including Tesco, Sainsbury's and Marks & Spencer, played down the scale of the current problem. Tom Ironside, its director of business and regulation, told Reuters: "BRC members adhere to all rules and regulations on promotions, ensuring consumers benefit from genuine savings on the discounts offered."

Burnham indicated the agenda would continue. "Today is just the start," he said.

For brokers, the combined signal from Westminster and the FCA is clear: transparency in add-on sales and renewal communications is a compliance floor, not a best-practice aspiration, and the auto-renewal cancellation parity requirement specifically is the easiest place to start checking today.

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