Finance Editor, Kael Tripton Ltd - LBS MBA - Verified against FCA Handbook: 14 June 2026
Quick answer
Two FCA rules now protect against unfair renewal pricing: ICOBS 6B (from January 2022) bans renewal prices above new customer equivalents; Consumer Duty Outcome 2 (from July 2023) requires overall fair value. The FCA's pricing review found loyal customers were paying PS4 billion per year more. Both rules can be cited in a renewal pricing complaint to the insurer and FOS.
How Consumer Duty and the Price Walking Ban Work Together on Renewals
Direct answer
How do Consumer Duty and ICOBS 6B protect me on insurance renewals?
ICOBS 6B (from 1 January 2022) bans charging existing customers more than new customers. Consumer Duty Outcome 2 (from 31 July 2023) additionally requires the price to represent fair value overall. Both rules apply simultaneously. A renewal that matches the new customer price but is still above market fair value may breach Consumer Duty even if it complies with ICOBS 6B. Cite both rules in any renewal pricing complaint to the insurer or FOS.
FCA Handbook - ICOBS 6B.3.1 - Verbatim Rule Text Source: handbook.fca.org.uk
A firm must not charge a renewing home insurance or motor insurance customer a renewal price that is higher than the equivalent new business price for that product.
Get your renewal notice and note the premium
Also note the exact cover -- excess, sum insured, add-ons.
Get a new customer quote from the same insurer
Use their website directly. If lower than your renewal, ICOBS 6B may be breached.
Get quotes from two or three other major insurers
For equivalent cover. If the market is materially cheaper, this supports a Consumer Duty fair value challenge.
Write to the insurer citing both ICOBS 6B and Consumer Duty
State the renewal price, new customer equivalent, and market comparison. Request a fair value assessment.
Escalate to FOS if unresolved within 8 weeks
Reference both rules in your FOS submission.
| Rule | What it prohibits | What it requires | Challenge route |
|---|---|---|---|
| ICOBS 6B | Renewal above new customer price | Nothing -- it is a ban | Complaint to insurer + FOS |
| Consumer Duty Outcome 2 | Nothing specific | Demonstrate fair value proportionate to benefit | Complaint to insurer + FOS |
| Combined | Both above | Both above | Cite both rules in every renewal pricing complaint |
Related KT guides
Frequently Asked Questions
How has Consumer Duty changed home insurance renewal pricing?
Consumer Duty Outcome 2 (effective 31 July 2023) works alongside the FCA's price walking ban (ICOBS 6B, effective 1 January 2022) to create dual protection against unfair renewal pricing. ICOBS 6B prohibits charging existing customers more than new customers. Consumer Duty goes further by requiring insurers to conduct a fair value assessment across their entire product range -- so even if the renewal price matches the new customer price, the insurer must still demonstrate that the overall price level represents fair value.
What did the FCA find in its pricing review?
The FCA's 2019-2021 general insurance pricing review found that loyal customers were paying on average PS4 billion per year more than new customers for home and motor insurance. Insurers were systematically using price optimisation algorithms to identify loyal customers and charge them more. The price walking ban (PS21/5) and subsequent Consumer Duty requirements aim to eliminate this practice permanently.
Can I challenge my renewal using both rules?
Yes. A well-constructed renewal pricing complaint cites both ICOBS 6B (if the renewal exceeds the new customer equivalent) and Consumer Duty Outcome 2 (if the overall price appears disproportionate). The FOS considers both rules when adjudicating renewal pricing complaints.
How do I check if my renewal complies with Consumer Duty?
Obtain a new customer quote from the same insurer's website. If the new customer quote is lower than your renewal, the renewal may breach ICOBS 6B. If both are similar but above the market rate, this may be a Consumer Duty fair value issue. Compare against at least two other major insurers for equivalent cover to establish a market benchmark.
What is the difference between ICOBS 6B and Consumer Duty on renewal pricing?
ICOBS 6B is a specific prohibition: renewal price must not exceed the new customer equivalent. Consumer Duty Outcome 2 is a broader positive obligation: the insurer must demonstrate the overall price represents fair value proportionate to the benefit. ICOBS 6B catches the most obvious price walking. Consumer Duty catches situations where the market price level for loyal customers is too high even when new and existing customers are charged the same.
Primary sources
Kael Tripton Ltd is registered with the Information Commissioner's Office under registration number ZC135439.
