Life CCC sanctions insurer over inaccurate and delayed annual notices
Life Code Compliance Committee
The Life Insurance Code Compliance Committee (Life CCC) has sanctioned a life insurer after more than 10,000 breaches meant customers received annual notices that were inaccurate, incomplete or issued late.
Between August 2024 and January 2026, the insurer failed to include relevant policy benefits, accurately describe some customers’ premium arrangements and issue notices before policy anniversary dates.
In total, the insurer reported 10,105 breaches of the Life Insurance Code of Practice.
Chair of the Life CCC, Jan McClelland AM, said annual notices provide customers with important information about their life insurance.
“Customers rely on these notices to understand what their policy covers, what they are paying and whether anything has changed,” Ms McClelland said.
“When that information is wrong, incomplete or arrives late, customers can be left uncertain about the insurance protections they are relying on.”
The failures occurred during a large-scale migration of legacy insurance products and reflected weaknesses in the insurer’s systems, compliance oversight and assurance arrangements.
Delays by a third-party provider engaged to distribute the notices accounted for 4,686 of the breaches.
The insurer first identified the issue following a customer complaint. Its subsequent investigation uncovered further breaches, which it reported as its review progressed.
Ms McClelland said significant operational changes required careful planning, effective controls and active compliance oversight.
“Product migrations can involve complex systems and large volumes of customer information, but they must not compromise the accuracy or timeliness of essential communications,” Ms McClelland said.
“Insurers need controls that prevent errors, monitoring that identifies problems early and clear oversight of every party involved in delivering these communications.”
The Life CCC issued the insurer with a formal warning and required it to demonstrate that its governance, controls and assurance arrangements are sufficient to prevent the problems from recurring.
The insurer has updated its annual notices, corrected policy information and issued communications and corrected notices to affected customers. It has also taken steps to improve its systems, monitoring and oversight of the third-party provider.
The Life CCC will assess whether these actions are effective and capable of preventing further non-compliance.
Ms McClelland said the sanction reflected the scale and duration of the breaches, the weaknesses that allowed them to occur and the importance of the Code commitments involved.
“A formal warning puts the insurer on notice that these failures were serious and that stronger enforcement action may follow if further non-compliance occurs,” Ms McClelland said.
“It is not enough to correct individual notices after problems have affected thousands of customers. The insurer must show that it has addressed the underlying weaknesses and can meet its commitments in practice.”
The case reinforces that insurers remain responsible for meeting their Code commitments when they engage another organisation to perform activities on their behalf.
The Life CCC expects insurers to maintain effective controls over annual communications, apply appropriate assurance during system changes and actively monitor third-party providers. Insurers should also use proactive monitoring to identify emerging issues before they become widespread or are revealed through a customer complaint.
Read the case summary.
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The Life CCC is an independent body established to monitor compliance with the Life Insurance Code of Practice. Its purpose is to ensure consistent and high-quality service standards are maintained for the benefit of consumers. This also works towards increasing trust and confidence in the life insurance industry.
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