FCA Consultation CP26/33: Minor Changes to General Insurance Value Measures Reporting

At a Glance

The FCA’s CP26/33 consultation proposes removing two reporting fields from the General Insurance value‑measures regime - the top‑2% claim‑pay‑out amount and the names of the five largest distribution arrangements - with an optional transition for 2026‑27 data and a mandatory start in the 2028 reporting year. The practical control implication is that firms should document scope, governance and implementation assumptions before deciding whether a response is appropriate under CP26/33.

The FCA’s post‑implementation review of the 2021 value‑measures rules found that the data improve transparency and support fair‑value assessments, but inconsistencies in reporting have limited comparability. To address this, the regulator is seeking feedback on two narrowly scoped changes that would cut administrative effort without materially reducing the usefulness of the published data set.

These proposals are directed at firms that currently submit value‑measures data - insurers, intermediaries and managing agents - as well as Gibraltar‑based and Temporary Permission firms that fall under the same reporting obligations. The consultation closes on 9 October 2026, and the FCA signals a wider review of the rules in the first half of 2027.

What the FCA Is Proposing

Removal of top‑2% claim‑pay‑out metric

The consultation proposes to delete the requirement for firms to report the amount (in £) that the top 2 % of claim pay‑outs exceed for each product. The FCA notes that this figure is not published and is rarely used in supervisory analysis, yet firms have reported calculation difficulties and resource‑intensive validation. MEMA recommends that firms assess whether their current data‑collection pipelines include this metric and, if so, plan to disable it for the 2026 and 2027 reporting cycles, recognising that it will become mandatory to omit from 2028 submissions.

Deletion of the five largest distribution arrangements disclosure

The second proposal removes the obligation to name the five largest distribution arrangements for each product. The FCA states that this information is not published and adds limited supervisory value, while increasing administrative load. Affected firms need to review contractual data feeds from distribution partners and adjust any reporting templates to make the field optional for 2026‑27 and fully excluded from 2028 onward.

Transitional optional reporting

The FCA introduces a transitional provision that makes both proposed fields optional for the 2026 data (due 28 February 2027) and the 2027 data (due 28 February 2028). This approach is intended to avoid short‑term system changes for firms that have already built the metrics into their processes. Companies should therefore decide now whether to continue reporting the metrics voluntarily during the transition or to cease collection immediately, documenting the rationale for audit purposes.

Who Should Read This Consultation

The FCA identifies the following groups in its "Who this is for" section: This applies to general insurance firms that report value measures data, including insurers, intermediaries and managing agents. It's also relevant to other stakeholders such as trade bodies, consumer organisations, research companies and price comparison websites.

MEMA recommends using the FCA's stated audience to document why the consultation is relevant to the firm's permissions, activities or service-provider relationships, without treating consultation readership as the final scope of rules that have not yet been made.

MEMA Assessment

MEMA recommends that the board ask whether the firm’s current reporting architecture relies on the top‑2 % claim‑pay‑out amount or the five largest distribution arrangements for internal performance monitoring. If those metrics feed into pricing models or distribution‑partner reviews, Boards can also consider the impact of losing that data source and whether alternative analytics are required before the mandatory 2028 change.

A second board question concerns cost‑benefit: does the resource saved by dropping these fields outweigh the value of maintaining a longer historical series for strategic insight? Evidence needed includes the cost of system changes, the frequency of supervisory queries on these metrics, and any downstream reporting that references them. The board’s decision should be recorded in the regulatory‑change register and reflected in the firm’s risk‑assessment framework.

Questions Firms Should Resolve

MEMA recommends that firms begin by mapping the two proposed data fields to existing data‑capture systems. If the top‑2 % claim‑pay‑out amount is generated through a separate calculation engine, the optional transition allows an immediate switch‑off, but the firm must retain evidence of the decision for internal audit. Similarly, the distribution‑arrangement list often resides in partnership‑management databases; removing it from the reporting template reduces the need for periodic validation against partner contracts. MEMA recommends a gap‑analysis workshop within the next two weeks to confirm where these fields sit in the data flow and to document any downstream impacts on management information or regulatory dashboards.

The optional period creates a decision point for each reporting cycle. Companies that have already invested in automated extraction of the top‑2 % metric may choose to continue reporting voluntarily for 2026 and 2027 to preserve historical continuity, while others may cease collection to avoid unnecessary cost. MEMA advises senior leadership to weigh the benefit of maintaining a consistent data series against the resource savings, and to capture the chosen approach in the firm’s regulatory‑change register. By the 2028 reporting year, the omission will be mandatory, so any system that still expects the fields must be re‑engineered well before the 2029 submission deadline.

Decisions Before the Consultation Closes

Source Evidence

Plain English Glossary

• CP - Consultation Paper. FCA publication setting out proposed rule changes and inviting feedback from industry and the public.

Disclaimer

This article is for general information only and does not constitute legal or regulatory advice. Firms should assess the application of regulatory requirements by reference to their permissions, products, customers and operating model.

How MEMA Can Help

MEMA can help firms translate regulatory change into practical controls, policies, monitoring activity and board evidence. Book a free scoping call to discuss what this development means for your firm.

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Further reading: the FCA's 2026 compliance priorities.