The draft General Insurance Code of Practice (GICOP) is one of the most significant changes to customer standards in the Australian insurance industry for many years. Much of the discussion has understandably focused on what has changed. The more practical question, however, is how insurers and underwriting agencies should prepare.

Having worked through several major regulatory reforms over the past few years—from RG271 to CPS 230—I’ve found that successful implementation rarely starts with rewriting policies. It starts with understanding the scope of the project.

The draft Code is no different.

In this article

If you’re preparing for the new General Insurance Code of Practice, I recommend focusing on seven implementation projects:

• Map your products against the new Code definitions.
• Confirm which parts of your business are actually captured by the Code.
• Review customer documentation.
• Reassess vulnerable customer processes.
• Review claims operations.
• Include suppliers and delegated authorities in your implementation program.
• Update governance, reporting and training.

For some organisations, this will become one of the largest operational projects in recent years. For others, particularly specialist underwriting agencies, the exercise may be considerably smaller than expected.

1. Does the new General Insurance Code actually apply to your products?

This is the first question every insurer and underwriting agency should answer.

One of the biggest changes in the draft General Insurance Code of Practice is the introduction of new definitions of Retail Insurance and Wholesale Insurance. These definitions are unique to the Code and should not be confused with the retail and wholesale concepts used under the Corporations Act.

That distinction has received surprisingly little attention, yet it could have the biggest impact on your implementation project.

Many insurers and underwriting agencies, particularly those writing specialist or commercial business, may discover that products they assumed would be covered by the Code are no longer within its scope. In some cases, businesses may find that only part of their portfolio is covered. Others may find that the Code no longer applies at all.

I suspect many implementation projects will start by reviewing policies and procedures. Personally, I think that’s backwards.

The first deliverable should be a product register.

List every product you distribute and classify it using the Code’s definitions—not the Corporations Act. Once you’ve completed that exercise, identify which business units, customer journeys and operational processes remain within scope.

Only then will you know the true size of the implementation project.

Practical tip: Don’t treat this as a legal exercise. Involve product managers, underwriting, distribution and compliance. They often have different views about how products are positioned in the market, and those discussions will help identify areas requiring legal review.

2. If your products are captured, customer documentation should be your next priority

Once you’ve established that a product falls within the Retail Insurance definition, the next project is reviewing customer documentation.

One of the most significant reforms is that much of the new General Insurance Code is intended to become contractually enforceable. Customers will need to be informed that the insurer has agreed to comply with an enforceable Code, meaning Product Disclosure Statements, policy documentation and other customer-facing communications should all be reviewed.

This work extends well beyond legal wording.

Product teams, compliance, customer experience, marketing and legal all need to be involved to ensure the same commitments are reflected consistently across every customer touchpoint.

This is also a good opportunity to review complaint information, financial hardship information and other customer support material against the new requirements.

Preparing for the new Code requires more than updating documents—it requires a clear connection between obligations, controls, customer processes and evidence. See how the Curium Compliance Platform helps insurers and underwriting agencies turn regulatory requirements into practical, trackable workflows.

3. The biggest operational change may be vulnerable customers

Every insurer already has a Vulnerable Customer Policy.

The challenge isn’t writing another one.

The challenge is recognising vulnerability consistently.

One of the most important concepts introduced by the draft General Insurance Code is situational vulnerability. Rather than focusing only on characteristics of an individual, the Code recognises that customers may become vulnerable because of their circumstances.

Think about a customer whose home has been destroyed in a bushfire or flood.

A family dealing with a total loss after a major fire.

Someone involved in a serious liability claim.

A customer experiencing domestic and family violence.

These customers may never previously have been considered vulnerable, yet the circumstances surrounding their claim may require a very different approach from the insurer.

For many organisations, this will require much more than updating a policy.

Claims consultants need to know what signs to look for.

Customer service teams need to understand when additional support should be offered.

Systems need to allow vulnerability to be recorded appropriately.

Managers need confidence that customers are receiving consistent treatment across the organisation.

In my view, this is likely to become one of the most resource-intensive implementation projects arising from the new Code.

4. Review the entire claims journey—not individual chapters of the Code

The draft General Insurance Code introduces changes across multiple aspects of claims handling, including customer communication, cash settlements, expert reports, catastrophe response, family and domestic violence, nominee arrangements and complaints.

Rather than reviewing each requirement individually, I would recommend mapping the Code against your existing claims journey.

Start from First Notification of Loss.

Then work through every stage of the customer experience.

Where does the new Code introduce a different expectation?

Where do existing processes already meet the requirement?

Where are new controls needed?

Looking at the customer journey rather than the legislation usually produces a much clearer implementation plan.

Mapping the new Code across the entire claims journey can reveal gaps that are difficult to identify through policies and spreadsheets alone. See how Curium can help your team connect obligations, claims processes and evidence in one place—book a personalised demo.

5. Include suppliers and delegated authorities from the beginning

One mistake I often see during regulatory implementation is focusing only on internal teams.

The customer experience doesn’t begin and end with the insurer.

Depending on the product, customers may deal with builders, repairers, assessors, investigators, claims administrators, legal providers or delegated authority partners. From the customer’s perspective, these organisations are all part of the same insurance experience.

That makes supplier oversight an important part of implementing the new General Insurance Code.

Review supplier agreements, onboarding processes and oversight activities to make sure external providers understand the standards expected under the Code. At the same time, consider whether existing file reviews, audits and performance reporting provide enough evidence that those standards are being applied consistently.

6. Complaint handling is no longer just about meeting RG271

Most insurers have invested significant effort implementing RG271 Internal Dispute Resolution.

That work remains valuable.

The new General Insurance Code, however, raises another question.

Are you confident you’re identifying every complaint?

Complaints now arrive through multiple channels—email, phone, online forms, brokers, delegated authorities and claims suppliers. If complaints are missed at the point of receipt, the rest of the complaints process becomes irrelevant.

The same principle applies to vulnerability and systemic issues.

The organisations that perform well under the new Code are likely to be those that identify issues early rather than simply responding to them once they’ve been formally reported.

7. Governance shouldn’t be the last workstream

Every major regulatory change eventually reaches the Board.

The new General Insurance Code should be no different.

As implementation progresses, Boards and senior executives will want assurance that the organisation is ready.

That means reviewing governance arrangements, management reporting, implementation tracking, staff training, assurance activities and Code breach reporting before commencement—not afterwards.

Many organisations already have governance frameworks developed for CPS 230 and recent breach reporting reforms. Those frameworks provide an excellent starting point, but they should be reviewed to ensure they also capture the new obligations introduced by the General Insurance Code.

Common implementation mistakes

From the discussions I’ve had with insurers and underwriting agencies, these are the mistakes I’d try to avoid:

• Assuming the Corporations Act definitions determine whether the Code applies.
• Starting with policy updates before completing product mapping.
• Treating vulnerability as a claims issue rather than an organisation-wide responsibility.
• Forgetting suppliers and delegated authorities.
• Waiting for the final Code before beginning implementation planning.

Frequently Asked Questions

Does the new General Insurance Code apply to all underwriting agencies?

No. The first step is to assess each product against the Code’s Retail and Wholesale Insurance definitions. Some specialist underwriting agencies may find that only part of their portfolio is covered, while others may fall outside the scope of the Code altogether.

What is the biggest change in the new General Insurance Code?

From an implementation perspective, I believe the biggest change is not any single chapter. It’s the combination of new product definitions, enforceability of the Code and the expanded expectations around vulnerable customers and customer care. Together, they require changes across claims, customer service, product, governance and supplier oversight.

When should insurers start preparing?

Implementation planning can begin now. Product mapping, process reviews and gap analysis do not depend on the final wording of the Code and are likely to save considerable time once the commencement date is confirmed.

Author:
Tetiana George, CEO of Curium, Co-Chair of Insurtech Australia and member of ASIC Digital Finance Advisory Committee. LinkedIn Profile.