The Consumers’ Federation of Australia says the National Insurance Brokers Association draft code of practice, released with a discussion paper, “needs substantial work” if it is to become a benchmark for others.

“The framing of the code as being between the subscriber and NIBA, with no rights created for consumers, is curious, unhelpful and inaccurate,” the federation says in a submission. “A code fundamentally comprises a series of commitments from subscribers to consumers.”

The submission says the proposed re-written code “is too often written in a hedged way so as to reduce the strength of subscribers’ commitments” and the independent reviewer should use that version to identify NIBA’s substantive position on issues, rather than as the foundation for the next iteration.

Consumer groups says the code should commit subscribers to avoiding and preventing conflicts of interest altogether, rather than explaining them, and with new Australian Securities and Investments Commission enforceability rules, all code provisions should be enforceable, rather than only certain parts.

More work is also required on the complaints section of the document, they say.

“We welcome the ambition to provide more clarity about the complaints process, but the relevant section of the draft code is a very long way from being fit for purpose,” it says.

The submission says a focus on vulnerability in the next iteration is welcome and it supports the suggestion of a statement by NIBA on the ambition of the code.