FCVic has made a submission to the Insurance Council of Australia’s consultation on the draft General Insurance Code of Practice. The submission draws directly on the experience of Victorian financial counsellors supporting people through insurance claims after major disaster events, including the January 2026 Victorian fires and the October 2022 floods, as well as those supporting victim-survivors of family violence and households in severe financial hardship. We warmly thank the members who shared their casework insights and feedback through the FCVic Disaster Recovery Network — their generosity has allowed us to coordinate a truly member-led submission, and the twenty recommendations put forward are grounded in their frontline expertise.

While FCVic supports the objective of modernising industry standards, the submission raises serious concerns that the draft Code weakens existing consumer protections in several places and does not adequately address the recommendations of the Independent Review or the Parliamentary Inquiry into insurers’ responses to the 2022 major floods claims. Key recommendations include replacing discretionary language with mandatory obligations, requiring insurers to use a customer’s nominated method of communication, mandating acceptance of a standard authority form, extending protections to eligible small businesses, inserting a dedicated section on temporary accommodation entitlements, and ensuring expert reports are provided to consumers without delay or unnecessary redaction. FCVic supports the recommendations made in the joint consumer submission led by Financial Rights Legal Centre, and the submission by Financial Counselling Australia on vulnerability.

This submission should be read in conjunction with our earlier work on insurance and natural disasters:

• Unsettled: Climate Risk and Cash Settlements in Home Insurance
• Submission to the Independent Review of the 2020 General Insurance Code of Practice
• Submission to the House Standing Committee on Economics Inquiry into Insurers’ Responses to 2022 Major Floods Claims
• Submission to AFCA’s Joint Consultation on General Insurance Approaches
• Submission to AFCA’s Consultation on Approach to General Insurance Claims Handling
• Submission to the Insurance Brokers Code of Practice Review
• Submission to Treasury’s Consultation on Standard Definitions and Standard Cover for Insurance