The General Insurance Code Governance Committee (CGC) says measures introduced to assist customers experiencing vulnerability and financial hardship should be reviewed in the wake of implementation.

The CGC says the new Code of Practice obligations that came into effect this year represent some of the most significant changes in the overall update and responses shouldn’t be seen as one-off steps “simply to be completed”.

“The 2020 Code does not require code subscribers to conduct a post-implementation review,” it says in a report. “However, given the importance of these new obligations, the committee considers it is an important exercise that code subscribers should undertake to ensure these obligations are being met in practice.”

The new measures, in Parts 9 and 10 of the code, took effect from January 1, but the CGC says it was disappointed not all insurers met the deadline, despite plenty of notice and with heightened vulnerabilities due to the pandemic.

There has also been “some confusion” around Part 10, with 13 code subscribers saying they didn’t believe they had to comply with the section due to their business models and the nature of their interactions with consumers, it says.

“The committee will continue to engage with these code subscribers to better understand their business models and determine whether they are in breach of their code obligations,” it says.

The review found 86% of subscribers met the deadline for introducing vulnerability measures in Part 9, which applies to retail insurance, while 85% were on time in implementing hardship standards in Part 10, applying across retail and wholesale.

The CGC says it continues to see concerning conduct around the recovery of money from uninsured consumers who are experiencing hardship.

Firms have been urged to remind collection agents and solicitors of obligations to comply with the new code standards when recovering debts from people experiencing vulnerabilities.