Consumers with Pre-Existing Medical Conditions (“PEMCs”) have long faced barriers when purchasing travel insurance, including higher premiums, exclusions or outright refusals. To address this, the Financial Conduct Authority (FCA) introduced rules in Policy Statement PS20/3 requiring firms, in certain circumstances, to signpost consumers with PEMCs to a directory of specialist insurers.
The aim was to improve access for consumers with more serious PEMCs, enabling them to find suitable and affordable cover. The FCA anticipated that this would benefit those who were previously unable to purchase insurance or who faced exclusions, and that in some cases consumers would obtain more competitive pricing.
Recently, the FCA published a review evaluating how these rules have performed identifying what has worked well, where shortcomings remain and what changes will apply from 2026. For insurers, intermediaries and consumer advocates, this represents an important compliance and strategic moment.
What the FCA Review Found
In its post-implementation review, the FCA assessed how effectively firms have implemented the signposting requirements and their impact on consumer outcomes.
- Positive but muted impact
The FCA concluded that the intervention has had a net positive effect, though the overall impact has been less than expected:
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- The FCA estimates that an additional 21,000 policy sales may have resulted from the rules; and
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- Some consumers who were previously unable to obtain cover, or faced exclusions, now have access to broader options.
- Gaps in compliance and consumer experience
The review found that not all firms have met the standards required. Instances of non-compliance or weak implementation were identified:
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- Some consumers still experience difficulties finding appropriate cover; and
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- Poor signposting journeys persist, including ambiguous referrals, broken links or outdated directory information.
- Updating thresholds and directory rules
The original rules required signposting when a medical condition increased the premium by more than £100. The FCA intends to update this threshold to reflect inflation and market conditions:
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- From 1 January 2026, the trigger will increase to £200, and it will be reviewed every five years in line with the Consumer Prices Index (CPI); and
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- The FCA will also introduce a “one entry per firm” rule for directories to reduce duplication and improve usability.
- Ongoing monitoring and enforcement
The FCA will continue to enforce compliance and work with directory providers to enhance the consumer journey and the quality of directory content. Firms identified as non-compliant may face supervisory intervention.
Why This Is a Strategic Moment for Insurers and Intermediaries
Adapting to these developments is not only a compliance requirement but also a strategic opportunity to demonstrate consumer focus, transparency and trustworthiness.
Opportunities and Strategic Priorities
- Demonstrate consumer-centricity
Firms that effectively support consumers with PEMCs can strengthen brand reputation and customer loyalty.
- Optimise referral journeys
Ensure that signposting pathways, whether online, via call centres or through intermediaries, are clear, functioning and user-friendly. Faulty links or unclear language undermine the FCA’s intent and risk regulatory criticism.
- Use data to refine processes
Monitor where and when signposting is triggered and track conversion rates and outcomes. Use this data to inform product design, underwriting criteria and customer communications.
- Stay ahead of regulatory change
With the 2026 changes approaching, firms should audit systems, customer communications and compliance processes well in advance. Early preparation avoids last-minute disruption and demonstrates regulatory diligence.
- Educate intermediaries and staff
Ensure all relevant staff, including brokers, advisers and customer service teams, are trained to identify PEMC cases, understand when signposting applies and guide customers appropriately.
Preparing for the FCA’s Updated Rules
To comply with the updated signposting requirements, firms should:
- Reassess referral logic to ensure that signposting triggers align with the new £200 premium threshold;
- Test and verify all consumer-facing links and referral buttons, ensuring visibility and accuracy;
- Integrate with directory providers effectively, whether through APIs or seamless web handovers;
- Develop monitoring tools to track referral volumes, completion rates, and customer feedback;and
- Maintain consistency across departments through internal guidance and periodic compliance reviews.
Firms should also ensure that all consumer communications use plain, accessible language, reflecting the FCA’s expectations under Principle 12 and the Consumer Duty. Early system updates and internal training will minimise compliance risk as the January 2026 deadline approaches.
How Complyport Can Help
Complyport supports insurance intermediaries, underwriters and other regulated firms in aligning their processes with the FCA’s signposting, Consumer Duty and communication standards. Our experts can assist with:
- Regulatory gap analysis: Assessing how your current travel insurance processes align with PS20/3 and ICOBS requirements.
- Consumer Duty integration: Embedding fair value and consumer understanding principles within your signposting and communication frameworks.
- Policy and procedure development: Updating signposting policies, referral scripts, website content, and customer documentation in line with the 2026 changes.
- Compliance training: Delivering tailored staff training on PEMC signposting, vulnerable customers, and FCA expectations.
Book a meeting with one of our Subject Matter Experts today.
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