The Act will reform and consolidate consumer law in the United Kingdom (UK). For insurers offering consumer products the main impact of the Act is likely to be seen in the new laws for digital content and ancillary contracts, unfair contract terms and the changes to the mechanisms for consumer redress.
The Consumer Rights Act 2015 complements, but is distinct to, the measures introduced by the European Consumer Rights Directive. For most firms the new consumer law will not have a significant impact on their business. Many of the measures reflect much of the Financial Conduct Authority (FCA) best-practice in terms of policy wording and Treating Customers Fairly. But this is a major piece of legislative reform that does introduce some changes that insurers should be aware of. In particular firms should be aware of the introduction of rules to ensure that digital content is fit for purpose, changes to consumer cancellation rights and the requirement to make all potentially onerous core terms ‘prominent’.
The Consumer Rights Act 2015 forms the centrepiece of UK consumer law reform. The UK Government has supported the introduction of reform measures in order to boost consumer confidence.
We will be sharing our briefing on the impact of the Act for insurers shortly.