At a time when the NEW GI Code and NIBA Brokers Code of Practice are occupying the general insurance headlines, ASIC and APRA have released their 2026-27 Corporate Plans.
In this article I analyse the regulators plans and the impact on the general insurance industry.
I consider what the plans mean for APRA‑regulated general insurers and other AFSL holders in the general insurance ecosystem (underwriting agencies, claim managers, and brokers).
ASIC and APRA are converging on a pathway that can be summarised as: support productivity and innovation, but raise the bar on resilience and outcomes and make compliance easier for those acting in good faith while being less forgiving where harm occurs.
ASIC frames its approach as being “easier to deal with” for those who want to comply and “harder to avoid” for those who cause harm. APRA’s plan emphasises safety and stability, strong risk management and governance, and the need to respond to intensifying cyber and AI threats and service provider dependencies.
The result is that general insurance regulation is increasingly “end‑to‑end”: prudential resilience and market conduct are being treated as mutually reinforcing, not separate lanes.
1) The shared themes that affect everyone in general insurance
(A) Operational resilience is becoming a common regulatory language
ASIC states it will consult on proposals to “better align operational resilience market integrity rules with APRA standards” and continue harmonisation work.
APRA identifies cyber and AI threats as intensifying, and highlights increased reliance on common platforms and material service providers (through CPS 230).
Practical implication: regulators will increasingly test whether an organisation can maintain critical services through disruption (catastrophes, cyber events, vendor outages), and whether third‑party dependencies are properly controlled, not just whether policies exist.
(B) AI shifts from ‘innovation’ to ‘governance, security and outcomes’
ASIC signals support for “responsible innovation” and “safe and responsible use of AI”, and notes investment in ASIC’s own AI and digital capability.
APRA similarly identifies AI as a key priority and aims to become an “AI-enabled regulator”, while tying frontier AI to heightened cyber threats.
Practical implication: AI use in client servicing, underwriting, claims, complaints and customer communications will be examined for explainability, control, auditability, and the way it changes consumer outcomes and operational risk.
(C) Simplification and coordination: fewer duplicative asks, less tolerance for ‘confusion’
ASIC commits to ‘simplification practices’ and improving guidance accessibility and usability, and notes coordinated surveillance and streamlined data requests with APRA through Council of Financial Regulators collaboration.
APRA likewise emphasises coordination to reduce duplication and references the Regulatory Initiatives Grid.
Practical implication: expect improved visibility of regulatory priorities and more standardised information gathering, but also clearer lines of accountability when systemic issues persist.
2) Impacts for APRA‑regulated general insurers
(A) Prudential expectations will bite hardest where outsourcing and catastrophe operations are weakest
APRA is explicit that cyber and AI risk is intensifying and that reliance on common technology platforms and material service providers increases systemic concentration risk.
That has direct consequences for insurers’ outsourcing models: delegated claims administrators (insurance claims managers), catastrophe response vendors, cloud providers, data analytics platforms and underwriting tech stacks.
What “good” will look like in practice: demonstrable continuity for critical services (notably claims and complaints) during peak stress, and evidence that third‑party risk and vendor resilience are actively monitored and governed.
(B) Conduct and outcomes scrutiny remains a parallel track (and will intersect with prudential issues)
ASIC’s plan emphasises preventing consumer harm and effective enforcement. ASIC commentary around the plan highlights the need to address ‘poor practices by insurers’, with particular sensitivity where premiums rise and claims and complaints experiences deteriorate.
Intersection point: operational resilience failures (system outages, vendor failures, catastrophe surge breakdowns) increasingly manifest as conduct problems, that is: delays, poor communications, inadequate investigations, insurers should expect less regulatory patience with ‘operations-caused’ consumer harm.
(C) Expect rising expectations for AI controls in underwriting and claims
ASIC’s “responsible AI” framing and APRA’s “AI-enabled regulator” ambition point to a higher supervisory baseline for model governance, particularly where AI influences pricing, claim outcomes, fraud triage or vulnerability identification.
3) Impacts for other AFSL holders operating in general insurance (underwriting agencies, claim managers, brokers)
Even where a firm is not APRA‑regulated, ASIC’s signals and the broader APRA agenda matter because: (i) ASIC is focused on consumer harm, including in insurance contexts; (ii) resilience expectations are becoming ‘table stakes’ for any entity handling sensitive data or critical customer functions; and (iii) many AFSL holders sit inside insurers’ third‑party ecosystems and will be pulled into insurer uplift programs.
(A) Underwriting agencies (MGAs/coverholders): delegated authority won’t dilute accountability
ASIC’s consumer-outcomes posture and APRA’s focus on third‑party dependencies combine to increase scrutiny on delegated models where underwriting agencies design, distribute and (where licensed) influence claims processes.
Likely pressure points: product governance, distribution oversight, complaint and IDR capability, and operational resilience of platforms used for underwriting workflows and client communications.
(B) Insurance claim managers and claims handling service providers: “claims intermediaries” are in scope
ASIC has signalled “new work across insurance claims intermediaries in disaster-affected communities.”
That points to heightened scrutiny of timeliness, communications, documentation quality, complaint handling and escalation practices especially in catastrophe conditions where consumer detriment is amplified.
Operational resilience overlay: claim managers will also feel APRA-driven uplift indirectly through insurer counterparties demanding stronger cyber controls, business continuity, surge capacity and vendor assurance because claims is a critical operation for insurers (under CPS 230) and disruptions translate quickly into consumer harm.
(C) Insurance brokers: cyber, communications and complaint handling remain core licence risks
ASIC’s “resilient financial system” and simplification agenda, and the broader regulatory focus on data security and AI risks, indicates that governance of cyber controls, third‑party risk (CRM platforms, quoting tools, email security), and AI-assisted communications is increasingly central to AFSL compliance.
Brokers also sit at a key “expectations management” point for claims and complaints; where insurers are under pressure on claims practices, broker communications and handovers can become a regulatory and reputational flashpoint.
Key takeaways (twin peak regulators, same direction)
- APRA‑regulated insurers should plan for deeper scrutiny of resilience, cyber and AI and third‑party risk, with increasing practical linkage to claims and complaints outcomes.
- Across the ecosystem, AI and operational resilience are becoming “non-negotiable” governance topics, and simplification and coordination between regulators will likely reduce duplication while increasing clarity and accountability.
Bottom line: both Corporate Plans point in the same direction: regulators want general insurance markets that can withstand disruption (cyber, catastrophe, vendor failure) while delivering fair, efficient customer outcomes. For insurers that means direct prudential and conduct expectations; for other AFSL holders it means targeted ASIC focus plus increasing “flow-down” expectations from APRA‑regulated insurers, especially in claims and disaster contexts.
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