General Insurance Code of Practice — Policyholder Rights

The General Insurance Code of Practice (GICP) is a voluntary industry code developed by the Insurance Council of Australia (ICA) that sets minimum standards for how member insurers must treat their customers. The 2020 version of the Code — the current version — significantly expanded policyholder protections compared to its predecessors, with stronger provisions around claim timeframes, vulnerable customers, and complaints handling.

The Code is binding on ICA member insurers, which includes most of Australia's major general insurers. When an insurer subscribes to the Code, compliance becomes a contractual obligation — and breaches of the Code can be referred to the Australian Financial Complaints Authority (AFCA) and, in systemic cases, to ASIC.

The Code covers a wide range of general insurance products, including home and contents, motor, travel, and commercial insurance. It does not cover life insurance, health insurance, or products governed by other industry codes. For those products, separate codes apply.

You can verify whether your insurer is a Code subscriber and access the full text of the Code on the Insurance Council of Australia's website at insurancecouncil.com.au.

The GICP creates a range of specific rights for policyholders. The most practically important for claimants dealing with disaster recovery are:

• 10-day cooling-off period: For most retail insurance products, policyholders have a 10-business-day cooling-off period after purchasing a policy or renewing on different terms. During this period, you can cancel without penalty as long as no claim has been made. This right is separate from and additional to any rights under the Corporations Act.
• Internal dispute resolution (IDR) — 30-day timeframe: When you lodge a complaint with your insurer, the insurer must respond with its IDR decision within 30 calendar days for most complaints. For complaints involving complex investigations, the insurer may request an extension — but must give reasons and advise you of your right to escalate to AFCA if you are not satisfied with the extension request.
• Claim decision — 10 business days for straightforward claims: For claims that the insurer accepts are straightforward, the insurer must make a claim decision within 10 business days of receiving all required documentation. Where additional investigation is required, the insurer must keep you informed of progress at least every 20 business days.
• Written reasons for decisions: If your insurer declines your claim, reduces payment, or imposes conditions, you are entitled to the reasons for that decision in writing. The reasons must be specific enough to allow you to assess whether the decision is consistent with your policy terms.
• Independent repair assessments: The Code includes provisions entitling policyholders to seek an independent assessment of repair costs where there is a dispute about scope or pricing. This right is practically significant in managed repair situations where the insurer's preferred contractor and the policyholder disagree about what work is needed.
• Hardship assistance: Insurers must have processes to identify and assist customers experiencing financial hardship as a result of a claim shortfall, payment difficulty, or disaster circumstances. This includes provisions for interim assistance where a full claim decision has not yet been made.

Part 9 of the GICP contains specific obligations around customers who are in vulnerable circumstances. The Code defines vulnerability broadly — it is not limited to permanent disability or financial disadvantage, and explicitly includes situational vulnerability arising from circumstances such as being in the immediate aftermath of a natural disaster.

• Identifying vulnerability: The Code requires insurers to train their staff to recognise signs of vulnerability and to adjust their approach accordingly. The obligation is not contingent on the customer formally declaring themselves vulnerable — insurers are expected to identify and respond to apparent vulnerability.
• What vulnerability covers: The Code identifies a non-exhaustive list of circumstances that may indicate vulnerability, including: recent trauma (such as loss of property in a disaster), cognitive impairment, language barriers, domestic and family violence, financial stress, age, and health conditions affecting decision-making capacity.
• Support obligations: Where vulnerability is identified, insurers must make reasonable adjustments to their processes — for example, allowing more time for decisions, accepting communication through a support person, providing information in alternative formats, and avoiding high-pressure tactics. Urgency and pressure are specifically prohibited in interactions with vulnerable customers.
• Referral to support services: Insurers must have the ability to refer customers to relevant support services — including financial counselling, legal aid, and crisis services — where appropriate. This obligation applies throughout the claims process, not just at point of sale.

If you believe an insurer failed to respond appropriately to circumstances that indicated vulnerability, this is a specific ground for a complaint under the Code and a basis for an AFCA dispute.

Code breaches are handled through a combination of internal complaints processes, AFCA dispute resolution, and — for systemic issues — the Code Governance Committee (CGC) and ASIC.

• Internal complaints first: Before escalating to AFCA, you must have lodged a complaint with the insurer's internal dispute resolution process and either received an unsatisfactory response or waited the relevant IDR timeframe (generally 30 days) without resolution. Keep a written record of the date you lodged the complaint and all subsequent communications.
• AFCA referral: AFCA can consider whether an insurer has complied with its Code obligations as part of a complaint. A Code breach does not automatically mean the insurer must pay more — but it is directly relevant to AFCA's assessment of whether the insurer acted fairly and in accordance with good industry practice. AFCA can order insurers to pay compensation for non-financial loss, including distress and inconvenience caused by poor claims handling.
• Code Governance Committee: The CGC monitors insurer compliance with the Code and can sanction member insurers. Sanctions range from remediation requirements to public naming. The CGC publishes annual reports on Code compliance that include aggregate data on breach types — useful context for understanding whether the conduct you experienced is systemic.
• ASIC for systemic breaches: ASIC can investigate and take enforcement action where insurer conduct constitutes a systemic breach of the Code combined with a breach of the Corporations Act or the ASIC Act. ASIC enforcement can result in licence conditions, enforceable undertakings, or civil penalty proceedings.

Knowledge of your Code rights gives you a practical tool in claims disputes. When an insurer is slow, unresponsive, or unreasonable, citing the Code in your communications puts the insurer on notice that you are aware of its obligations — and creates a documented record for any subsequent AFCA complaint.

• Write, don't call: Create a written record of every material interaction. If the insurer has exceeded the 10-business-day decision timeframe for a straightforward claim, or has not updated you within the 20 business day progress update window, write to the insurer citing the Code provisions and requesting a response within a specified period.
• Request written reasons: If your claim is declined or reduced, request written reasons in specific terms. If the reasons are vague or do not address your policy terms, write back requesting clarification and reference the Code obligation to provide specific reasons.
• Escalate internally first: If your case manager is unresponsive, escalate within the insurer — ask to speak to a supervisor and lodge a formal complaint through the insurer's IDR process. This starts the 30-day IDR clock and creates the formal record needed for AFCA.
• Keep everything: Save all written communications, correspondence, assessments, and your own notes of verbal interactions (date, time, who you spoke to, what was said). This documentation is essential if you proceed to AFCA.

AFCA is Australia's free external dispute resolution service for financial complaints, including insurance disputes. Once you have completed the insurer's IDR process (or the 30-day window has passed), you can lodge a complaint with AFCA at afca.org.au.

• When to escalate: You can escalate to AFCA when you have received the insurer's IDR decision and are not satisfied with it, or when the IDR timeframe has elapsed without a decision. You do not need to wait for the 30 days in all circumstances — certain urgent matters (such as someone without shelter due to a home loss) can be escalated earlier on hardship grounds.
• What AFCA considers: AFCA assesses complaints against the insurer's policy terms, applicable law, the General Insurance Code of Practice, and general principles of fairness and good industry practice. This means AFCA can find against an insurer even where the insurer has technically complied with its policy terms, if its conduct was unfair in the circumstances.
• What AFCA can order: AFCA can direct an insurer to: pay a claim it declined, pay a higher amount, re-assess or reinspect, vary its decision, and pay compensation for non-financial loss (distress and inconvenience). Monetary limits apply — for insurance, the limit on monetary awards is $1,085,000 for most complainants as at the 2026 limits. AFCA cannot order an insurer to act outside its policy terms, but it can hold the insurer to a fair interpretation of those terms.
• AFCA determinations are binding: If you accept AFCA's determination, it is binding on the insurer. You are not bound by it — you can reject a determination and pursue court proceedings instead, but in practice AFCA resolution is faster and cheaper than litigation for most insurance disputes.

This guide is informational and does not constitute legal or financial advice. If your claim dispute is large or complex, consider seeking independent legal advice before accepting any settlement or AFCA determination.