Rules and trust9 min read
Insurance renewal reminder texts for brokers
Insurance renewal reminder texts for brokers: what the FCA pricing rules changed, ICOBS renewal notices, auto-renewal, PECR and texts that work around them.
In short
- Since 1 January 2022, ICOBS 6B.2.1R has said a firm must not set a home or motor insurance renewal price that is higher than the equivalent new business price.
- The FCA's July 2025 evaluation found existing home insurance customers paid £49.17 more on average than new customers after its pricing reforms, down from £95.38 before.
- In FCA data for 2022 to early 2024, 70% of home insurance policies and 77% of motor policies were set to auto-renew by default at the start of the policy term.
- ICOBS 6.5.1R requires a consumer renewal notice to show the new premium beside last year's, in writing or another durable medium and in good time before the renewal.
- Under ICO guidance, an automatic renewal notice that is worded neutrally and does not encourage the customer to renew may not count as direct marketing.

Insurance renewal reminder texts used to be part of a guessing game. Before 2022, the FCA found home and motor insurers using "price walking", raising prices for renewing customers year after year "without the knowledge of some consumers". Its pricing rules, set out in policy statement PS21/5 in May 2021, ended that for home and motor insurance from 1 January 2022: ICOBS 6B.2.1R says "a firm must not set a renewal price that is higher than the equivalent new business price". The FCA's own evaluation, published in July 2025, found the gap had almost halved in home insurance and reversed in motor.
What hasn't changed is that a policy ends on a fixed date, and someone has to look at the renewal before then. The FCA's data also shows that 70% of home policies and 77% of motor policies were set to auto-renew by default after the reforms. A reminder text from the broker is the nudge that gets the renewal pack opened. It sits under the ICOBS renewal rules, the Consumer Duty and PECR, and all three point the same way: the text tells the client what's happening and when, and the paperwork does the rest.
What changed with the pricing rules
ICOBS 6B applies to any firm setting a home or motor renewal price for a consumer, setting the price of add-ons offered at renewal, or "determining the level of remuneration, including in particular any fees earned by the firm when distributing a product at renewal" (ICOBS 6B.1.1R). That last part brings brokers into the chapter as well as insurers. The rule applies "at the point the renewal notice is prepared", and ICOBS 6B.2.5R makes the firm assume the customer came back through the same channel they first used.
EP25/2, the FCA's evaluation, compared policy data from 2019 to 2021 with 2022 to the first quarter of 2024.
- New customers
- Existing policyholders
Mean total price at policy inception in the FCA's insurance pricing data, a sample of policies from participating firms. Unweighted averages, not adjusted for inflation. The pricing rules took effect on 1 January 2022.
Source: FCA, EP25/2: An evaluation of our GIPP remedies, July 2025, tables 2 and 3
See the figures as a table
| New customers (£) | Existing policyholders (£) | |
|---|---|---|
| Home, 2019 to 2021 | 176.64 | 272.02 |
| Home, 2022 to 2024 Q1 | 222.36 | 271.53 |
| Motor, 2019 to 2021 | 458.24 | 437.48 |
| Motor, 2022 to 2024 Q1 | 569.38 | 460.19 |
In home insurance, existing policyholders paid £272.02 on average before the reforms against £176.64 for new customers, a gap of £95.38. Afterwards the figures were £271.53 and £222.36, a gap of £49.17. The FCA's reading is that existing customers' prices "remained stable in home and rose only slightly in motor, despite high inflation", while new customers' prices rose. In motor the order flipped. New customers had paid £20.76 more than existing ones; afterwards they paid £109.19 more, which the FCA puts down to renewing motor customers being lower risk on average and no longer being overcharged for it.
The evaluation is careful about what it claims. It found the rules "statistically significantly associated with a decrease in consumer prices in the motor market", worth an average of £6.63 a policy, and no significant link with home prices. It doesn't say renewal prices are always the best deal available, and the renewal notice still has to tell long-standing customers to shop around.
What the renewal notice has to say
ICOBS 6.5.1R applies when a firm proposes to renew a consumer's general insurance contract lasting 10 months or more, and it applies to the broker as well as the insurer where the broker is dealing with the consumer at renewal (ICOBS 6 Annex 1). "In good time before the renewal", the consumer must get:
- the premium to be paid on renewal
- last year's premium (adjusted for any mid-term changes), set out so the two can be "easily compared"
- a statement that they should check the cover is still right for them and can compare prices and cover with other providers
- a statement saying whether the policy will renew automatically or whether they need to act to accept it
From the fourth renewal on, the notice carries a fixed sentence: "You have been with us a number of years. You may be able to get the insurance cover you want at a better price if you shop around." All of it has to be clear and accurate, "in writing or another durable medium", and presented in a way that "draws the consumer's attention to it as key information".
That's a document, and it should stay one. A text can't hold the premium comparison and the required statements in a way that meets those presentation rules, and a text that quotes this year's premium on its own, with nothing beside it, leaves out exactly the comparison ICOBS 6.5.1R exists to make. So the reminder points to the notice and says what to do with it.
Auto-renewal and the right to stop it
ICOBS 6.2.6R, in force since 1 January 2022, requires firms to tell consumers before the contract starts whether the policy auto-renews, what that means for them, and that they have "the right to cancel the automatic renewal element of the policy at any time", with the conditions, the consequences and "the practical instructions for exercising it". Private medical and pet insurance are excluded. PS21/5 adds that the ways a consumer can cancel auto-renewal "must include the methods by which a consumer is able to take out a new policy".
Two things follow for a text. A reminder to a client on auto-renewal should say plainly that the policy will renew unless they act, and how to stop it. And if a client replies to that text asking you not to renew, it's sensible to treat the reply as their instruction and confirm it, whatever the rules say about the minimum set of methods.
The reverse case matters as much. Some policies don't auto-renew, and a client who assumes they do can find themselves without cover. A text a week before the end date to anyone who hasn't accepted is one of the more useful messages a broker can send.
The Consumer Duty, and is it marketing?
PRIN 2A.5 applies the Consumer Duty's outcome on consumer understanding to all communications, in any channel, including after the sale. Firms have to communicate "in good time for retail customers to make effective decisions", including "at suitable points throughout the lifecycle of the product" (PRIN 2A.5.5R), and must satisfy themselves that the channel gives customers "an appropriate opportunity" to review information and assess their options (PRIN 2A.5.6R). Renewal is the obvious suitable point, and pairing a short text with the full notice is a reasonable way to meet both rules.
On PECR, the ICO's direct marketing guidance lists among messages that may not be marketing "automatic renewal notices that are worded neutrally and don't encourage customers to renew", and messages "advising customers in a factual way of the options available to them at the end of their contract without encouraging or promoting one option over another". A text saying the renewal documents are in the client's inbox and the policy renews on a date fits. A text pushing them to renew, or adding "ask us about landlord insurance", is marketing. For marketing to your own clients the soft opt-in usually covers it, as long as you gave them a way to opt out when you took their details and in every message. Our post on service text or marketing text works through the borderline cases.
Insurance renewal reminder texts that work with the notice
For a broker called Pennington Insurance, with names and dates merged in. None quotes a premium.
When the renewal notice goes out, about four weeks before the end date:
Pennington Insurance: your home insurance renewal for 14 Dec has been emailed to you. It shows this year's premium next to last year's. Please check the cover still suits you, and reply CALL if you'd like to talk it through.
A week before, for a client on auto-renewal:
Pennington Insurance: your car insurance renews automatically on 14 Dec. If you don't want it to renew, reply NO RENEW or call us before then. Your renewal documents are in your email.
A week before, for a policy that needs accepting:
Pennington Insurance: your car insurance ends on 14 Dec and won't renew unless you accept the renewal. Reply YES and we'll call to confirm it, or call us if you've arranged cover elsewhere.
When a detail is missing:
Pennington Insurance: to finish your van insurance renewal we need this year's mileage. Please reply with it, or call us. Renewal date is 14 Dec.
And once it's done:
Pennington Insurance: your car insurance has renewed from 14 Dec. Your new documents are in your email. Any questions, just reply here.
The broker's name opens every text, so the client knows who it's from before reading on. None of them carries a policy number, a premium, a registration or an address, so nothing useful leaks if someone else sees the phone. Every one either asks a single question or confirms a single fact, and none tries to sell an add-on.
Running it from your broking system
Renewal dates are the most predictable thing a broker holds, which makes the texts easy to automate. In CaptiFi Connect, texts can be scheduled up to a year ahead, so a broking system can queue the reminders when a policy goes on cover or when the renewal notice is issued, through the API's schedule_at time on POST /messages. Cancel a scheduled text and the credits come back, which covers mid-term cancellations. Replies such as NO RENEW, YES or a mileage figure land in a shared two-way inbox for whoever handles renewals, and a webhook can pass them back into the broking system.
One thing to plan for: when someone texts STOP, CaptiFi Connect puts the number on the account's opt-out list and later sends to it are refused, service reminders included. If a client who has opted out still wants renewal reminders by text, they can text START to come off the list; otherwise their renewal contact goes by email or post. Each text keeps a delivery report, a record of when the client was reminded and whether the handset received it.
Mortgage brokers have similar date-driven rules; our post on mortgage rate expiry reminder texts covers MCOB.
Common questions
Can an insurance broker send renewal reminders by text?
Yes. A neutral reminder that the renewal is due and the documents have been sent is likely to be a service message under ICO guidance. The text should point to the renewal notice, because ICOBS 6.5.1R requires that notice to set out the premium comparison and statements in writing or another durable medium.
Can a renewal price be higher than the new customer price?
Not for home or motor insurance sold to consumers. ICOBS 6B.2.1R, in force since 1 January 2022, says a firm must not set a renewal price higher than the equivalent new business price, assessed when the renewal notice is prepared.
What does the shop around statement on a renewal notice say?
From the fourth renewal onwards, ICOBS 6.5.1R requires: "You have been with us a number of years. You may be able to get the insurance cover you want at a better price if you shop around." It has to appear alongside the premium information.
Did the FCA pricing rules close the gap between new and existing customers?
In the FCA's July 2025 evaluation, existing home insurance customers paid £49.17 more on average than new ones in 2022 to early 2024, down from £95.38 in 2019 to 2021. In motor, new customers paid £109.19 more than existing ones afterwards.
Sources
Read for this post on 4 November 2026.
- FCA: EP25/2, An evaluation of our General Insurance Pricing Practices (GIPP) remedies, July 2025
- FCA: PS21/5, General insurance pricing practices market study, feedback and final rules, May 2021
- FCA Handbook: ICOBS 6, product information (ICOBS 6.2.6R auto-renewal, ICOBS 6.5.1R renewals)
- FCA Handbook: ICOBS 6B, home insurance and motor insurance pricing
- FCA Handbook: PRIN 2A.5, Consumer Duty outcome on consumer understanding
- ICO: direct marketing guidance, identifying direct marketing
- ICO: Guide to PECR, electronic mail marketing
Written by the CaptiFi Connect team. Published 4 November 2026. More in Rules and trust
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