The General Insurance Code of Practice is monitored and enforced by the Code Governance Committee (CGC) (paragraph 165 GI Code). The CGC’s constitution, functions and powers are set out in its Charter (paragraph 166).
The CGC comprises:
- a consumer representative – Julia Davis
- an industry representative – Dallas Booth
- an independent chair – Veronique Ingram
The Code Governance Committee Association Inc. (Association) powers and obligations are set out in the Charter (clause 5 Constitution).
A management committee is responsible for controlling and managing the affairs of the Association. (clause 7 Constitution)
CGC Charter
The Code Governance Committee (CGC) is a committee of the Code Governance Committee Association Inc.
The CGC is responsible for (Charter clause 1.2):
(a) providing stewardship of the Code by helping the general insurance industry understand and comply with the Code;
(b) identifying areas for improvement of insurance practices;
(c) liaising with the ICA on relevant matters;
(d) providing quarterly reports to the ICA Board;
(e) publishing an annual public report containing aggregate industry data and consolidated analysis on Code compliance
The CGC is also responsible for monitoring and enforcing compliance with the Code through (Charter clause 1.3 ):
(a) investigations, analysis of data, analysis of evidence and stakeholder engagement;
(b) receiving, investigating and making decisions about alleged breaches and giving Code Subscribers the opportunity to respond to any allegations that they have breached the Code;
(c) considering whether it is more appropriate for ASIC or another enforcement agency to investigate an alleged breach of the Code;
(d) agreeing with Code Subscribers on any corrective measures to implement within an agreed timeframe;
(e) imposing sanctions; and
(f) publishing breach decisions on a de-identified basis.
The CGC is responsible for monitoring and enforcing compliance with the Code in the manner set out in the Code. Without limiting the CGC’s Code functions and powers, the CGC may for the purposes of monitoring compliance with the Code (Charter clause 4):
(a) make reasonable requests for a Code Subscriber and/or the Service Provider to provide access to information, documents and systems, which the CGC considers necessary to discharge its functions;
(b) seek independent professional legal, accounting or other advice;
(c) request each Code Subscriber to lodge an annual data return and survey reporting on their compliance with the Code; and
(d) enter into appropriate arrangements with the Service Provider or AFCA for the purpose of facilitating:
(i) information exchange relevant to the CGC’s functions; and
(ii) referrals to the CGC of an allegation that a Code Subscriber has breached the Code
Additional powers CGC
- investigate Code Compliance (Charter clause 5)
- consider Code breaches (clause 5.3) and make breach decisions (5.4)
- impose sanctions (6.1)
- report Significant Breaches or serious misconduct to ASIC (6.2)
- publish significant breaches (7.1)
- publish an Annual report and provide to ICA Board and AFCA Board (9.2)
- develop policies, guidelines, reporting forms and operating procedure consistent with the Charter and Code (10)
CGC reviews
Upcoming review
Motor insurance claims handling
CGC are currently scoping a targeted review into motor insurance claims handling.
This targeted review aims to identify and address the underlying causes of rising motor insurance complaints—particularly complaints relating to motor vehicle repairers and the way insurers manage and respond to these issues.
Vulnerable consumers in temporary accommodation
CGC has commenced a thematic inquiry to assess how insurers meet their Code obligations to identify and provide additional support to vulnerable consumers in temporary accommodation.
The objective of this inquiry is to support improved industry practice by sharing findings, including any best practice examples, and recommendations to address any identified gaps.
CGC has sought information from five insurers and expect to publish a report on findings by the end of June 2026.
Efficient and effective claims handling
This review is examining the systems and processes of five insurers to assess how they proactively monitor individual claims to ensure they progress efficiently and effectively in accordance with the Code.
CGC has asked each participant to provide information about the oversight and processes they have to identify and address claims that may not be progressing efficiently and effectively.
CGC will be sharing the findings of this review directly with insurers and intend to conduct a follow-up review in 12 months to assess the participants responses to recommendations and see the effect of the changes on insurers management of claims.
Premium transparency
CGC has initiated a preliminary review of premium transparency after receiving a concern that an insurer’s policy documents may not adequately inform consumers of the cost difference between paying the policy premium annually versus monthly, and the additional costs associated with monthly instalments.
CGC has reached out to 20 insurers for information about their current processes to get an understanding of standard practice.
CGC found that six of the 20 insurers charge a different premium based on payment frequency and do not provide clear explanations to customers.
CGC followed up with these six insurers to better understand their disclosure practices and how many consumers are paying monthly as opposed to annually.
CGC expect to publish guidance based on findings, outlining best practice examples, expectations, and recommendations on how insurers can improve their premium transparency.
Debt collection
CGC has launched a preliminary review of the initial correspondence issued by insurers, or their collection agents, to consumers when seeking to recover money owed.
CGC wrote to 35 insurers seeking further information on their debt collection activities and seeking a copy of their template correspondence.
All relevant documents have been reviewed, and most letters were found to meet the Code requirements.
CGC are writing to 19 insurers regarding potential non-compliance with paragraphs 133 and 134.
CGC will assess this correspondence in line with the Code obligations and consider whether further work is required.
Annual reports, Guidance and Sanctions
News and publications can be found here
To help insurers improve their service to consumers and lift Code compliance, CGC publish a range of documents with detailed compliance guidance:
- Guidance notes elaborate on specific Code obligations – such as the financial hardship obligations in section 8 – setting out in more detail the Committee’s expectations and how CGC will assess compliance.
- Compliance reports detail the findings of the Committee’s own motion inquiries and desktop audits investigating areas such as internal dispute resolution, add-on insurance and outsourcing. These reports include detailed recommendations for Code subscribers.
- Annual reports offer a yearly overview of general insurance industry activity and compliance encompassing sales, claims, financial hardship and internal disputes. These reports include a number of recommendations for Code subscribers.
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