CCPC Public Liability Insurance Study Published

  • Measures required to improve transparency and encourage market entry
  • Study recommends a range of actions to benefit consumers and increase competition
  • The recommendations complement work underway as part  of the Action Plan for Insurance Reform

Wednesday December 23, 2020

The Competition and Consumer Protection Commission (CCPC) has today published its market study on the public liability insurance market. The CCPC commenced the study following a request from the then Minister for Enterprise, Trade and Employment, Heather Humphreys in July 2019.

The CCPC’s report examines the public liability market from a competition perspective. The report was informed by extensive stakeholder engagement and research which maximised the information available for analysis given the absence of independent data on the sector. The CCPC undertook market research amongst a large sample of public liability insurance buyers and used its statutory power under Section 18(1)(d) of the Competition and Consumer Protection Act 2014 to send requests for information to industry bodies. This approach has allowed the CCPC to identify the relevant competition issues in the market and make evidence-based policy recommendations. 

Speaking today, Isolde Goggin, Chairperson of the Competition and Consumer Protection Commission said,

“Premium increases and availability of public liability insurance have been the focus of significant concern amongst businesses, community groups, sports organisations and voluntary associations across Ireland in recent years. Our market study found that high percentage premium increases for public liability insurance are an issue across all sectors of the economy. While this finding is neither new nor surprising, the CCPC has been able to quantify the extent of the issue. Respondents to the CCPC’s market research experienced premium increases of on average 15-20% in the past three years.  In addition, reduced availability of public liability insurance seems to be primarily impacting certain sectors such as community and sports groups. 

The study found that a lack of independent, public data on the insurance market as well as a lack of open access to claims history information may be acting as barriers to market entry. The lack of data on the operation of the market causes problems for policy makers as they work to improve the market for public liability customers. The study also finds that customers should be supported to better engage with the market. It recommends that the role and remit of the Personal Injuries Assessment Board should be enhanced to provide a more stable and lower cost claims environment.

Based on the information gathered in the course of the study, the CCPC recommends a number of actions which complement the recently published Action Plan for Insurance Reform. We have designed these recommendations to build upon each other and if implemented they will have an increasingly positive impact on the market for public liability in the short to long term”.

  • Recommendation: Data availability

To ensure enhanced access to data and facilitate new market participation in the public liability market, the CCPC recommends:

  • That the Central Bank of Ireland (CBI) publish National Claims Information Database (NCID) information at insurer level. 
  • That the CBI develop its data collection exercise to provide aggregated information at subsector level, in future iterations of the NCID reports.
  • That access to the Insurance Link database be provided to all insurers in the market and that Insurance Link be managed by an independent body.
  • Recommendation: Develop supports for buyers

To allow for greater support for public liability insurance buyers, the CCPC recommends:

  • That the State should assist public liability buyers to become more engaged in the market by:
  1. Providing information to organisations on active public liability insurance providers;
  2. Assisting organisations in profiling their risk and identify possible options to reduce it, including the full suite of potential supply options in the market (the exact nature of the support here would need to be carefully considered so as not to encroach on the commercial activities of brokers), and;
  3. Improving choice for organisations by supporting greater market entry through the development of an international outreach programme to build confidence in the Irish market.
  • That the CBI review the approach used by insurers when implementing and communicating premium increases to ensure insurers are in compliance with their obligations.
  • That the Department of Finance and CBI consider how to facilitate entry to the market through ‘InsurTech’ and the potential development of ‘Open Insurance’.

It is important to note that such initiatives will not assist all public liability buyers who are currently experiencing large price increases or those who cannot obtain cover.

  • Recommendation: the Personal Injuries Assessment Board

In order to promote the development of a more stable and lower cost claims environment the CCPC recommends:

  • That the role of the Personal Injuries Assessment Board be expanded and enhanced to provide for it to become the main personal injury settlement channel in the State.

The CCPC’s report is available here


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