Fair4All Finance welcomes the FCA’s interim findings on the Pure Protection Market Study and strongly supports the focus on how well the market meets the needs of all consumers, particularly those in financially vulnerable circumstances. Pure protection products are essential financial safety nets that help households manage financial shocks, yet too many people remain excluded from the cover they need. The interim report highlights the scale of the protection gap, with 58% of adults holding no pure protection product and many having never considered their protection needs.
The FCA’s findings underline lower uptake and barriers to access among people with pre‑existing health conditions, renters, women, ethnic minorities, young people, the self‑employed and gig economy workers, and people who are digitally excluded. Affordability pressures, complexity in product information and limited access to trusted advice all contribute to lower uptake, mirroring our evidence that those in financially vulnerable circumstances are significantly less likely to hold any insurance or protection products.
We support the FCA’s consideration of potential options to reduce the protection gap, including awareness campaigns, prompts at key life events, and collaboration with trusted intermediaries. These interventions must explicitly address the needs of underserved groups. We also welcome further work on claims ratios, examination of switching practices, and measures to improve the claims experience, particularly for vulnerable consumers.
For the final phase of the Market Study, we recommend a stronger focus on underserved and excluded consumers, deeper insight into their lived circumstances, and targeted engagement with intermediaries such as credit unions, housing associations and debt advice charities. We encourage the FCA to support inclusive product design, innovation of products tailored to underserved groups, and clarity on regulatory support for new or bundled protection products. Fair4All Finance looks forward to contributing to the next phase of this work.
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