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title: "The Proposed 2026 General Insurance Code of Practice: What It Could Mean for Claims Operations"
description: The proposed 2026 General Insurance Code of Practice aims to enhance insurer accountability in claims handling, emphasising operational readiness and contractual obligations.
image: https://blog.codafication.com/hubfs/Blog%20Banners%20(62).png
---
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# The Proposed 2026 General Insurance Code of Practice: What It Could Mean for Claims Operations
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[Team Codafication](https://blog.codafication.com/author/team-codafication)
October 7, 2026
[Insurance](https://blog.codafication.com/tag/insurance) [Claims Management](https://blog.codafication.com/tag/claims-management)
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The proposed 2026 General Insurance Code of Practice signals a significant shift in insurer accountability across claims, supply chains and customer vulnerability. While the final Code is still subject to revision and ASIC approval, the direction of change gives insurers and their supply chain partners a clear indication of where operational readiness will matter.
The Insurance Council of Australia (ICA) released a fully redrafted General Insurance Code of Practice for public consultation in June 2026. That consultation has now closed, with the ICA considering stakeholder feedback ahead of an expected submission of a revised Code to ASIC for approval later in 2026.
This is more than a routine compliance refresh. The proposed Code introduces significant changes across claims handling, supply chain governance, vulnerability support and expert report standards. Importantly, if approved in its proposed form, many Code obligations would become contractually enforceable through insurance contracts for the first time.
For claims leaders, supply chain managers and transformation teams, the proposed Code provides a strong indication of how expectations around claims operations are evolving: away from service standards and policy-level commitments alone and towards measurable, evidenced operational accountability across the claims lifecycle.
Below, we at Codafication unpack some of the key proposed changes, what they could mean in practice and where insurers can begin assessing their operational readiness now.
**Why the Proposed GICOP Matters**
The redraft follows industry reviews and inquiries that identified opportunities to strengthen claims handling, customer communication and support for people experiencing vulnerability.
The ICA’s Industry Action Plan, released in March 2025, helped establish the direction for reform, with the proposed 2026 Code translating many of those commitments into more detailed obligations.
One of the most significant proposed changes is contractual enforceability.
Subject to ASIC approval and the final form of the Code, most Code obligations would become incorporated into insurance contracts. This would shift many requirements beyond industry standards overseen through Code governance and create potential contractual consequences for non-compliance.
The ICA’s consultation materials also anticipate a 24-month transition period to allow insurers to update Product Disclosure Statements, systems, processes and existing policy arrangements. However, the final commencement and transition arrangements remain subject to the final Code and ASIC approval process.
**Why This Is More Than a Compliance Refresh**
Previous Code revisions have strengthened disclosure and service expectations. The proposed 2026 Code goes further by placing greater emphasis on how insurers operationalise, monitor and evidence those commitments.
Proposals covering automatic acceptance of certain ageing claims, oversight of Claims Fulfilment Providers, Extra Care and vulnerability, cash settlements and expert reports all increase the importance of reliable operational data.
For insurers still relying on disconnected systems or manual processes to manage claim status, supplier performance, customer communication or complaints, the gap between current operations and future Code readiness could be substantial.
**Key Takeaways from the Proposed 2026 GICOP**
- Subject to ASIC approval, most Code obligations are proposed to become contractually enforceable through insurance contracts, increasing the consequences of non-compliance.
- Certain home and motor claims left undecided after 12 months would be automatically accepted, subject to defined exceptions.
- Claims Fulfilment Providers would be subject to strengthened requirements around suitability, licensing, training, performance monitoring, Code compliance and breach reporting.
The proposed Extra Care framework takes a circumstances-based approach to vulnerability, increasing the importance of identifying, responding to and evidencing customer support throughout the relationship.
- **Audit supplier governanceReview how provider suitability, licensing, training, performance, complaints and potential breaches are monitored. Identify where evidence is fragmented, manual or difficult to retrieve.**
- **Review cash settlement processes.Assess whether settlement methodology, supporting information and customer communications can be consistently documented and evidenced.**
- **Assess Extra Care workflows. Review how changing customer circumstances are identified, recorded and acted upon throughout a claim rather than solely at intake.**
- **Evaluate supply chain technologyThe direction of the proposed Code reinforces the importance of visibility across claims and the third parties involved in fulfilling them. Connected platforms can help centralise supplier information, surface emerging issues and maintain an auditable record of activity across the claims lifecycle.**
**How the Proposed Code Could Change Insurer Accountability**
The proposed Code contains several provisions that could move accountability further from policy-level promises and into day-to-day operational controls.
Two areas are particularly relevant for claims operations: claim ageing and expert report management.
**Why Ageing Claims Could Become a Bigger Operational Risk**
Under the proposed Code, certain eligible home building, home contents and motor vehicle claims that remain undecided after 12 months would be automatically accepted, subject to defined exceptions.
This proposal has the potential to transform claim ageing from primarily a service and operational performance measure into a more significant compliance and contractual risk.
For insurers, this increases the importance of knowing exactly where every applicable claim sits within its lifecycle.
Operational teams would need the ability to identify claims approaching relevant thresholds, understand the cause of delays and maintain evidence where an exception may apply.
Rather than relying on retrospective reporting, insurers may increasingly need real-time visibility, automated escalation and reliable records of claim activity.
**Why Expert and Assessor Delays Need Tighter Control**
The proposed Code incorporates requirements relating to the Insurance Council’s Expert Report Best Practice Standard and strengthens expectations around the management of External Experts.
If adopted, compliance with relevant expert report requirements would form part of an insurer’s broader Code obligations.
For insurers managing large networks of assessors and other experts, this increases the importance of tracking report turnaround times, identifying overdue assessments and maintaining clear records of communications and follow-up activity.
There is also an important distinction in relation to ageing claims.
Under the proposed Code, delays in obtaining an External Expert’s report may, in defined circumstances, form part of an exception to automatic acceptance where the insurer has used its best endeavours to obtain the report within the required timeframe.
That makes evidence critical.
Insurers need to be able to demonstrate not only that a report was delayed, but what actions were taken to obtain it and manage the claim while the delay occurred.
Connected claims and supplier systems can make that evidence significantly easier to capture than fragmented emails, spreadsheets and systems operating outside the core claim record.
**How the Proposed Code Raises the Bar for the Claims Supply Chain**
One of the most operationally significant areas of the redraft is the proposed treatment of Claims Fulfilment Providers.
This term encompasses third parties involved in fulfilling claims and introduces clearer expectations around how insurers select, manage and monitor the providers acting on their behalf.
**What Claims Fulfilment Provider Obligations Could Mean in Practice**
The proposed Code strengthens requirements around areas including provider suitability, relevant licensing, training, performance monitoring, compliance with applicable Code obligations and breach reporting.
Critically, insurers would retain responsibility for ensuring appointed providers meet the Code obligations that apply while acting on their behalf.
That shifts supplier governance beyond procurement and panel appointment.
Insurers may need stronger capabilities to verify provider requirements, monitor performance, capture complaints and issues, identify breaches and maintain evidence of appropriate oversight across their supply chains.
For insurers managing hundreds or thousands of suppliers across regions, trades and claim types, doing this consistently requires connected data and governance.
**Why Repair Quality and Complaint Handling Matter**
The proposed Code also strengthens expectations around the quality and management of claim fulfilment activities.
For insurers, supplier performance data, complaints, rectification activity and customer outcomes can provide important indicators of where issues are emerging within a supply chain.
Rather than viewing supplier performance and Code compliance as separate functions, the proposed framework reinforces the value of connecting them.
A provider repeatedly generating complaints, delays or rectification work is not simply creating an operational problem. It may also create increased compliance, customer and reputational risk for the insurer appointing them.
**What Could Improve for Insured Customers and People Requiring Extra Care**
Many of the proposed changes focus on the experience of people navigating insurance claims, particularly during complex or difficult circumstances.
The redraft proposes stronger protections around areas including cash settlements and support for customers who require Extra Care.
**Why Cash Settlements Need Stronger Safeguards**
The proposed Code strengthens requirements around cash settlement offers, including expectations around explaining how settlements work and providing customers with relevant information to help them make informed decisions.
Depending on the circumstances of the claim, this may include information relating to the scope of work, how the settlement has been determined, relevant risks and available review rights.
For customers, this is intended to create greater transparency at one of the most consequential decision points in a claim.
For insurers, it reinforces the need for consistent settlement methodologies, accessible supporting information and clear records demonstrating what was communicated to the customer.
**How Extra Care Changes Customer Support Expectations**
The proposed Code adopts a circumstances-based approach to vulnerability through its Extra Care framework.
Rather than treating vulnerability solely as a static customer category, the proposed framework recognises that a person’s circumstances and support needs can change.
Operationally, this increases the importance of identifying circumstances that may indicate a need for Extra Care, responding appropriately and maintaining evidence of the support provided.
For claims teams, that could mean reviewing training, workflow triggers, documentation standards and the way customer circumstances are captured across the lifecycle of a claim.
If relevant Code obligations become contractually enforceable, evidence becomes particularly important.
The question is not simply whether appropriate support was provided. Insurers may increasingly need reliable records demonstrating what support was identified, offered and delivered.
**What Insurers and Suppliers Should Do Now**
Public consultation on the proposed Code has closed, and the ICA is considering stakeholder feedback ahead of an expected submission of a revised Code to ASIC for approval later in 2026.
Until that process is complete, the final wording, approval and commencement arrangements remain subject to change.
That does not mean insurers need to wait before assessing their readiness.
There are several areas organisations can examine now:
**Map claim ageing visibility.**
Can your systems identify applicable open claims approaching significant ageing thresholds? Can teams quickly understand why a claim has been delayed and what activity has occurred?
**Operational Readiness Will Matter as Much as Policy Wording**
The proposed 2026 General Insurance Code of Practice represents a significant potential change in how the industry governs claims, manages supply chain performance and supports customers through difficult claim experiences.
The final Code has not yet been approved, and individual provisions may change as the ICA considers consultation feedback and progresses through the ASIC approval process.
But the direction is increasingly clear.
If approved broadly in its proposed form, greater contractual enforceability and stronger operational obligations would increase the importance of the connection between what insurers promise and what their systems, processes and data can demonstrate.
For insurers and supply chain partners, the anticipated transition period provides an opportunity to map proposed obligations against existing controls, improve visibility over ageing claims, strengthen supplier governance and build customer support requirements into live operational workflows.
Waiting for every detail to be finalised before examining those capabilities may leave organisations with considerably more work to do once implementation begins.
Operational accountability across the claims lifecycle is becoming increasingly important. Organisations that start assessing their readiness now will be better positioned to adapt once the final Code and implementation arrangements are confirmed.
Codafication’s Crunchwork is purpose-built to support connected claims and supply chain operations, centralising claims, suppliers and workflows within one platform while providing real-time visibility and automated integrations.
Reach out to Codafication to learn more:
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