The super complaint moment: why insurance firms need to rethink how they design for customers, not for processes

Rebuilding insurance design around genuine customer needs

The home and travel insurance sector is entering another period of scrutiny. The recent Which? super‑complaint prompted the FCA to publish its response in December 2025, and while the regulator has decided not to open a market study, it has been clear that insurers need to raise their standards on claims handling, sales oversight and customer understanding. The FCA’s own data shows firms are still struggling to deliver consistently fair outcomes, particularly for customers in vulnerable circumstances.

This moment is not about new rules. It is about the application of existing ones, especially Consumer Duty. And it is about whether firms have built the operational and cultural foundations to actually deliver good outcomes, rather than simply document them.

A widening gap between banks and insurers on customer satisfaction

The contrast between insurance and daily banking is becoming harder to ignore. Based on recent FCA data¹, Satisfaction with the complaints process was highest for day-to-day accounts (27% highly satisfied) and lowest for general insurance and protection (12% in 2024 vs 18% in 2022). This gap has been widening, not narrowing.

For home and travel insurance specifically, both FCA and FOS data showed worsening performance in the run‑up to 2024. That deterioration was reflected in Which?’s super‑complaint, which highlighted that insurers are still falling short of Consumer Duty expectations on claims handling and customer experience.

Why performance is slipping

Much of the industry’s challenge comes down to oversight and information. Many firms still rely heavily on outsourced claims handlers, yet lack robust oversight frameworks or meaningful management information. The result is inflexible, procedural, highly manual decision making that treats complaints as items to be closed rather than signals about where outcomes are going wrong.

The FCA’s 2024 thematic review of complaints and root cause analysis made this stark. Some firms viewed RCA completion as the end goal, not as a mechanism to decide what to change. Others made changes but could not show what impact those changes had or demonstrate how they were monitored. That mindset is incompatible with Consumer Duty’s expectation of continuous improvement.

The default customer problem

There is an additional question: who are firms designing for?

In May 2024, 26.4 million adults had characteristics of vulnerability, representing 49 percent of the UK population¹. This makes vulnerability the norm, not the exception. Yet many systems and processes still assume a “default customer” who is financially resilient, digitally capable and confident navigating complex products.

The reality is different.

• 24 percent of adults (13.1m) had low financial resilience in 2024¹
• 42 percent had limited savings buffers – they could not cover their living expenses for 3+ months if they lost their main source of household income¹

Only 61 percent of customers in vulnerable circumstances felt they had suitable ways to contact their financial services provider, compared with 72 percent of other customers².

When half of your potential customer base faces some form of vulnerability, you are no longer designing specialist support. You are designing for the mainstream.

A lack of proactive mindset

The FCA’s message could not be clearer. Firms must move beyond reactive corrections and into proactive experience design. And the regulator is not standing still. Following the Which? complaint, the FCA has expanded its work on claims supply chain management, sales processes and value measures. It plans deeper diagnostic work through 2026, including assessing how firms oversee outsourced providers and how product sales journeys affect consumer understanding.

The sector has reached a point where continuing to patch over issues is no longer an option.

What firms should do now: fix the structural issues

This is a moment to focus on operational reality, not regulatory interpretation.

1. Build products for the 49 percent.
   Stop treating vulnerable customers as the minority. Design product journeys that are flexible, accessible and reflective of the real distribution of customer needs.
2. Leave the default customer behind.
   Move away from designing systems around the hypothetical healthy, financially stable 30 year old homeowner. Build journeys that accommodate volatility, limited savings buffers and low confidence.
3. Modernise root cause analysis.
   Manual RCA is no longer fit for purpose. It should not be a tick box but an automated, intelligent capability that continually identifies themes and feeds them back into operational change. Tools like Huntswood’s automated Customer Experience Workspace make this possible in a way that integrates with real workflows rather than creating parallel ones.
4. Rebalance focus from completion to outcome.
   Shift attention from closing complaints quickly to addressing the conditions that created them. That is where better customer outcomes, higher satisfaction and reduced churn ultimately come from.

How firms prevent recurrence: compliant and best in class by design

The goal is not just to fix the immediate issues. It is to become the kind of firm that does not repeat them.

That means embedding preventative controls, not just corrective ones. It means designing operations that are compliant by design and smooth in execution, not reliant on hindsight. And it means combining operational delivery with strong oversight, independent assurance and the cultural expectation that experiences should improve continuously, not reactively.

Huntswood’s model is built to support that. Operations teams deliver scalable, resilient services for complaints, claims and customer experience. Advisory teams provide oversight, assurance and direction. Together, this allows firms to build capability that is not only compliant but consistently aligned with Consumer Duty expectations.

Final thought

The Which? super‑complaint has not triggered new rules, but it has highlighted a deeper truth. The sector’s risk is not regulatory non compliance. It is designing for a customer who no longer exists.

Now is the time for firms to reimagine what good looks like, modernise the way they learn from their own data, and create customer experiences that reflect the world as it actually is.