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FCA pet insurance rules 2026: what's changed and why
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In short
The FCA's 2022 price walking ban covers home and motor insurance only — it does not apply to pet insurance, so a pet renewal can legally be higher than the new-customer price. What does protect pet owners in 2026: mandatory annual fair value assessments, clearer renewal disclosure, and Consumer Duty. If your renewal looks unfair, you still have grounds to complain and escalate to the FOS.
Key takeaways
- The price walking ban (FCA Handbook ICOBS 6B) applies to home and motor insurance only — pet insurance is not covered by it.
- Insurers must conduct annual fair value assessments and act on the results.
- Renewal letters must clearly show last year's premium alongside this year's.
- Consumer Duty requires insurers to consider customer outcomes, not just compliance.
- Vulnerable customers (older owners, financially squeezed) get additional protections.
Correction, 3 July 2026: an earlier version of this guide said the FCA’s price walking ban had been extended to pet insurance. That was wrong — the ban applies to home and motor insurance only. The guide has been corrected throughout. Thanks to the reader who flagged it.
Two readers wrote in last month with the same story: a renewal letter, a premium up by more than a third, no plain-English reason given. In both cases we walked them through the FCA rules now in force and both got the price reduced without leaving the insurer. So this guide is both a summary of what’s actually on the statute book in 2026 and a working playbook for using it at your own renewal.
The rules that matter
Price walking ban (January 2022) — and why it does not cover pet insurance
The FCA banned “price walking” — charging existing customers more than new customers for identical cover — in January 2022. But the ban (FCA Handbook ICOBS 6B) applies to home insurance and motor insurance only. Pet insurance sits outside its scope, and that’s a detail a lot of coverage gets wrong.
The practical consequence: a pet insurer is not breaking any pricing rule if your renewal comes back higher than the price it quotes a brand-new customer for the same cover. There is no FCA cap tying pet renewals to new-business prices.
That does not leave pet owners unprotected. The rules that do apply to pet insurance — fair value assessments, the Consumer Duty, renewal disclosure and the vulnerable customer guidance — are covered below, and they still give you real leverage when a renewal looks out of line.
Fair value assessments (2021)
Insurers must conduct annual fair value assessments on every product line and act on the results. Where a product is consistently failing (for example, very high premiums against very low claim payout rates), the insurer has to redesign it or pull it.
The assessments have already had visible effects. Several cheap, narrow products that were technically legal but didn’t deliver good customer outcomes were quietly withdrawn between 2023 and 2025. A handful of low-cost accident-only lines disappeared off comparison sites in that window for exactly this reason.
Consumer Duty (July 2023)
The FCA’s Consumer Duty is a higher-bar regulatory standard. Firms have to act to deliver good outcomes for retail customers, not just stay inside the letter of the rules. For pet insurance the practical implications:
- Products must meet identifiable customer needs.
- Pricing must be fair value.
- Communications must be clear and not misleading.
- Customer support must be accessible.
- Vulnerable customers must be properly identified and supported.
36%
of general insurance complaints upheld by the FOS in 2024–25
Financial Ombudsman Service annual complaints data
The Duty is enforceable. Breaches can lead to FCA action and routinely show up in FOS decisions where the ombudsman cites the firm’s failure to act in the customer’s interests.
Vulnerable customer guidance
The FCA expects insurers to identify and support customers in vulnerable circumstances. The categories are deliberately broad: older customers, customers in financial difficulty, recent bereavement, physical or mental health challenges, caring responsibilities. In practice that translates to flexible payment terms, alternative communication channels, and more accommodation in claims handling.
What this means at renewal
If your renewal premium has jumped sharply, work through the steps below in order before deciding whether to switch.
1. Compare to a new customer quote for identical cover
Get the quote from your existing insurer’s website as if you were a brand-new customer for the same pet and exactly the same cover. For pet insurance the renewal is allowed to be higher — but a big gap is your strongest negotiating card, and evidence worth citing in a fair value or Consumer Duty complaint.
2. Read the fair value disclosures
Most UK insurers now publish fair value information in their annual reports or on their website. Compare your renewal to the average for similar pets. Where it sits well outside the range, ask the insurer to explain in writing.
3. Use the formal complaints process
If the insurer can’t justify the increase on fair value grounds, complain through the insurer’s formal process. Most have a 4 to 8 week response window. If you’re unsatisfied with the response, the Financial Ombudsman Service is the next step.
Owners often assume the renewal number is fixed. It rarely is. The FCA rules give you a real basis to ask “show me the working,” and a good number of renewals quietly come down once you do.
What this means at claim time
Three Consumer Duty implications worth knowing before you submit your next claim.
1. Clear refusal reasons
If a claim is refused, the insurer must explain in plain language why. A vague refusal citing “pre-existing condition” without specifics is a Duty breach and worth pushing back on in writing.
2. Reasonable claims handling timelines
The Duty requires firms to act in customers’ interests, which includes processing claims promptly. Routine claims taking more than 6 to 8 weeks without good reason can support a complaint.
3. Accessible support
Claims helpdesks must be reasonably reachable. If you can’t get through to query a refusal or chase a slow claim, that’s directly relevant to a Duty complaint and the FOS will look at it.
What this means for vulnerable customers
If you fit any vulnerable category, you can ask the insurer for: flexible payment arrangements (skipping a month, pausing direct debit), alternative communication routes (phone instead of online portal, paper instead of email), more accommodating claims handling (longer documentation windows, support filling in forms), and a named contact for ongoing support.
These aren’t nice-to-haves. They are explicit regulatory expectations under the FCA’s vulnerable customer guidance and the Consumer Duty. If the insurer doesn’t respond appropriately, that supports a Duty complaint.
How to escalate a complaint
Step 1: Formal complaint to the insurer
Every UK insurer has to operate a complaints process. Use it. Set out the issue, why you think it’s wrong, and the outcome you want. The insurer must respond within 8 weeks under FCA rules.
Step 2: Financial Ombudsman Service
If you’re unsatisfied with the insurer’s response, escalate to the FOS within 6 months of the final response letter. The FOS is free for consumers and decides cases on what’s fair and reasonable, not just on contractual technicality.
The FOS upholds a meaningful proportion of pet insurance complaints, particularly around ambiguous policy wording, pre-existing condition definitions, renewal pricing, and vulnerable customer treatment. The published FOS complaints data shows pet insurance hovering around the general insurance average uphold rate.
Step 3: FCA reporting
The FCA doesn’t typically intervene in individual disputes. That’s the FOS’s role. Systematic issues can still be reported via the FCA’s complaints route, and patterns of complaints can trigger a wider FCA investigation against the insurer.
What hasn’t changed
Three structural things the FCA has so far left alone.
Pre-existing exclusions remain legal
The FCA has not intervened on the universal pre-existing exclusion. Insurers have to define it clearly and apply it fairly, but the exclusion itself stands. ManyPets’ historic-condition rule is still the major commercial exception in the UK market.
Insurers can still raise renewal premiums
Provided the rises reflect legitimate factors (age, claims history, market vet fee inflation) and the product still represents fair value, the insurer is within its rights to raise the renewal — and for pet insurance there is no rule capping the renewal at the equivalent new-customer price.
Insurers can still leave the market
Several smaller and white-label brands exited the UK market in 2024 and 2025. Affected customers are usually moved to other brands within the same group with continuous cover, but a few have to find new policies and accept new pre-existing exclusions on conditions that had been covered.
What to do this week
If you have a renewal in the next 60 days, the highest-impact action is the new-customer quote check above. If your renewal is further out, it’s worth bookmarking the FOS complaints data link and the premium trends post so you have a sense of what a reasonable rise looks like before the letter lands. For a starting point on which insurers come out best on Consumer Duty in our own scoring, the 2026 best UK pet insurance list is the place to start.
See the brands meeting Consumer Duty cleanest
Our 2026 picks weight customer outcome quality alongside cover and pricing.
See the 2026 picks →Frequently asked questions
What is the FCA's price walking ban?
Introduced in January 2022, the ban stops insurers charging existing customers more than the equivalent new-customer price for identical cover. It applies to home and motor insurance only (FCA Handbook ICOBS 6B) — pet insurance is outside its scope, so a pet insurer can lawfully quote a renewal above its new-customer price. The fair value rules and Consumer Duty, which do apply to pet insurance, still require the overall price to represent fair value.
What is Consumer Duty?
The FCA's Consumer Duty (in force from July 2023) requires firms to act to deliver good outcomes for retail customers. For pet insurance, this means clear communication, fair pricing, products that meet customer needs, and proper customer support. Breaches can be enforced by the FCA and can support FOS complaints.
Can I complain about a renewal premium increase?
Yes. If your renewal increase looks materially out of line with similar pets and the insurer can't justify it, complain through the insurer's formal process. If unsatisfied, escalate to the Financial Ombudsman Service free of charge. The FOS upholds a meaningful proportion of pet insurance complaints around pricing and exclusions.
What protections do vulnerable customers have?
The FCA's vulnerable customer guidance requires insurers to identify and support customers who may be in vulnerable circumstances (older owners, financial difficulty, recent bereavement, mental health). Practical effects include payment plan flexibility, easier communication routes, and more accommodation in claims handling.