Another day, another raft of submissions published by the Hayne royal commission.

Some – but not all – submissions to its insurance policy questions document and Commissioner Kenneth Hayne’s interim report were uploaded to the commission website today.

The Insurance Council of Australia (ICA) made submissions to both, and the industry body comes out fighting.

While acknowledging the “unhappiness and financial cost to consumers” highlighted by case studies from the insurance round of hearings, ICA says these tales of woe were not representative.

It also warns against insurance being caught up in wider regulatory reform aimed at the banks.

“Lessons can always be learned,” ICA says in its interim report submission. “However, the case studies are not typical of the outcomes experienced by Australian policyholders.

“In seeking to address the causes of poor consumer outcomes, the Insurance Council submits that the approaches which may be appropriate to address issues in the banking or superannuation sectors should not be automatically applied to general insurance.

“In our experience, past broad-based reforms that have not taken into account the needs of general insurance consumers have created complexity in their application, to the detriment of consumers.”

ICA says “all of the policy issues raised in the general insurance hearings” are already being addressed.

“Questions such as the need for restrictions on commissions and protections from unfair contract terms have been closely considered for some time; discussion is ongoing because they are complex issues and unwarranted consequences need to be avoided.”

In its submission to the insurance policy questions document, ICA takes each suggested reform one by one.

It says, taking into account reforms already under way, further changes to the regulatory regime “are not required”.

It accepts the current disclosure regime “is not serving its purpose”, and says it supports a review of standard cover provisions.

The ICA says a ban on commission-based remuneration for the sale of retail general insurance “is not warranted” and no further restrictions on remuneration are required.

Add-on insurance sold through motor dealers should not be prohibited, but it supports a deferred sales model and cap on commissions.

ICA is “not opposed” to making the General Insurance Code of Practice mandatory for all insurers issuing products captured by the code, but says a breach of the code should not be treated as a breach of law.

Click here to see the submissions.