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COVID-19: Protecting insurance consumers in a crisis

26 June, 2020

As Insurance firms implement measures to navigate the COVID-19 landscape, it is imperative that they continue to comply with regulatory obligations and expectations. COVID-19 has presented a challenge to organisations in how they operate as businesses and how they engage with their customers. From an insurance perspective, the Central Bank of Ireland (CBI) has highlighted their expectations of firms. How would your organisation fare in a future inspection, in relation to its handling of the COVID-19 crisis?

A photo of the cable band, suspenders and the tower of the Samuel Beckett bridge in Dublin city.

The impact of COVID-19 has highlighted the importance of insurance in consumer protection.

The CBI has highlighted existing regulations, and reminded the industry of how regulatory compliance will protect consumers during this global pandemic. There are three areas of most relevance during COVID-19, according to the CBI:

  1. Customer engagement
  2. Complaints handling
  3. Operational resilience 

Customer engagement

The CBI expects insurance firms to be sensitive to changes in customer circumstances as a result of COVID-19. Firms should be transparent regarding levels of cover provided by policies, particularly at renewal stage.

Claims handling

The CBI has reminded insurance firms of their regulatory obligations under the Consumer Protection Code when processing insurance claims from customers. Firms are also expected to view government advice to close a business as a 'direction' to close.

Operational resilience

Firms are expected to ensure that consumer-facing areas of business operations are adequately resourced and sufficiently supported to ensure that customer needs are met. Policies are also expected to be put in place for positive engagement with customers who are experiencing difficulties.

What actions can insurance firms take to ensure that their regulatory obligations and CBI expectations are satisfied?

Customer-facing functions

Firms must ensure that all customer-facing staff are reminded to advise customers of key policy details. Staff being redeployed to business areas experiencing an increase in demand should be adequately trained and possess sufficient levels of expertise in order to competently provide customer assistance. 

Customers in difficulty or vulnerable consumers

Firms should continue to work within a customer-centric culture, for example, ensure that all claims are afforded due consideration. Firms should be prepared to revise what they regard as a "vulnerable consumer", beyond current definitions. COVID-19 is a unique pandemic resulting in a new rationale to categorise someone as "vulnerable". Some customers may have increased difficulties completing certain requests due to lack of access to relevant information as a result of COVID-19.

Business continuity plans

Firms must ensure continuity and regularity in the performance of their activities, in line with Solvency II guidelines. Firms are likely operating on a dispersed basis from offsite locations. Management must ensure that conducting operations in such a manner does not diminish their oversight of business conduct and that measures taken to address operational issues are not done at the expense of customer service standards.


Developments in countries or regions in which any outsourced functions are located, should be monitored continuously. Firms must be able to demonstrate contingency plans are developed to ensure that firms can continue to operate, at levels and standards expected by both customers and the CBI, in the event of outsourced functions abroad or 3rd party local outsourcers operating at a reduced capacity.

We are here to help you

Our team of regulatory experts, can support you to strengthen your consumer protection regulatory compliance. We can help you plan for the new normal, including development of a digitally enabled and agile workforce. We can help you to reimagine the possible. Contact us today.

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Sinead Ovenden

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 6422

Darren O'Neill

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 7521

John O'Leary

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 8659

Paraic Joyce

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 6394

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