Every Driver Buying No Claims Protection Could Lose CMA Disclosure Rules in November

• The Competition and Markets Authority proposes to scrap the rule that makes insurers, brokers and comparison sites tell drivers what no claims bonus protection does and does not cover.
• The CMA has said it expects to publish its decision on the Private Motor Insurance Market Investigation Order 2015 in November, and the 2015 rules stay in force until the CMA makes a variation order.
• Whatever the CMA decides, a driver buying protection can ask three questions: how many claims it allows, what it adds to the premium and what a claim does to the renewal price.

The warning you see at checkout could disappear

Any driver offered no claims bonus protection with a car insurance quote from August 2016 has met the wording. Before the buyer pays for the add-on, the insurer or broker has to say what it does and does not cover. The words come from a CMA order made in 2015, and the CMA now proposes to remove them.

The proposal sits in the CMA Provisional Decision of 12 August 2026, part of a review of 33 market remedies launched on 19 January 2026. The CMA gave notice of its intention to vary the Private Motor Insurance Market Investigation Order 2015 by revoking Part 2, which holds the point of sale disclosure duties, and Article 6.1(b) of Part 4, which makes insurers and brokers hand the regulator tables of average discounts every year.

Nothing has changed for drivers yet. The order is in force today, and Article 1.3 keeps it in force until the CMA varies or revokes it. The draft variation order in the provisional decision would take effect on the date the CMA publishes the signed final order. On 4 November 2026 the CMA published final decisions on 31 of the 33 remedies. Two were held back, and the private motor insurance order is one of them. The CMA wrote: “We are still considering consultation responses on two remedies, the Retail Banking Market Investigation Order 2017 and the Private Motor Insurance Market Investigation Order 2015. We expect to make and publish a decision on these remedies in November.”

What the 2015 order makes insurers say today

Article 3 of the order has applied from 1 August 2016. When an insurer or broker offers no claims bonus protection, it has to give the buyer a set statement and set information, clearly and prominently. A comparison site has to show its own shorter statement through a prominent link. If the offer is made by phone, the wording is spoken, and the written version follows with the policy documents once the buyer accepts.

The core statement, set out in Schedule 1a, reads: “No claims bonus protection does not protect the overall price of your insurance policy. The price of your insurance policy may increase following an accident even if you were not at fault.” A second statement follows on written offers: “No claims bonus protection allows you to make one or more claims before your number of no claims bonus years falls. Please see the step-back procedures for details.” The insurer has to explain its step back formula, through a prominent link on a website or email, or an enclosed description by post.

Comparison sites carry their own wording under Schedule 1b: “No claims bonus protection varies between insurers but in general it allows you to make one or more claims before your number of no claims bonus years falls (further information will be provided when you select a policy and proceed with the purchase of the policy on the provider’s website).” Schedule 1b adds the same warning that protection does not protect the overall price of the policy.

Schedule 2 asks more of insurers than the statement does. A written offer has to tell the buyer how much the protection adds to the premium, the number of no claims years declared, a table of the average discount the insurer awarded last year for each number of years, and a second table showing what happens to the buyer’s years after one or more claims, with and without protection. On the phone, the insurer has to give the price of the protection, the years on offer, the average discount and the number of claims the customer can make before the years are affected.

Why the CMA wants the rules gone

The CMA wrote the order after its 2014 investigation found that a lack of information and transparency about the costs and benefits of the protection left buyers unable to pick the best value offers. Insurers had less reason to compete on the price and terms of add-ons, and premiums ran higher.

Eleven years on, the CMA gives two reasons for change. The first is the market. Comparison sites have grown in scale and capability, so a driver can compare features such as no claims bonus protection with far greater ease and accuracy than in 2015. Personalised pricing now gives the buyer the key figures on protection without a mandated table. Aviva told the CMA that the average discount tables offered little real value and might even obscure customer understanding. The Association of British Insurers and Sabre made the point about comparison sites, and Arthur J Gallagher said that giving the information in a standard format online, by phone and in documents had become a market norm.

The second reason is regulatory. The FCA told the CMA that its Consumer Duty applies to FCA regulated firms, including insurers, and requires them to make sure communications meet customers’ information needs. The FCA described the Duty as outcomes based, with no prescriptive information requirements, and said firms must still give customers information that lets them make informed choices when buying products, no claims bonus protection included.

Who backs the change and who objects

The CMA received responses from nine parties: the AA, the Association of British Insurers, Andrew Yule Insurance, Arthur J Gallagher, Aviva, the British Insurance Brokers’ Association, MoneyNotion, PIB Group and Sabre. Four responses (the Association of British Insurers, Sabre, Aviva and Arthur J Gallagher) favoured removing Part 2. One, from the AA, favoured keeping the order. Four argued for dropping the annual compliance statement requirement under Part 4.

The brokers’ body BIBA wrote to the CMA on 8 September 2026, and the CMA published the letter with the consultation responses on 4 November. BIBA stated: “BIBA supports the CMA’s objective of reducing unnecessary regulatory burdens where remedies are no longer proportionate or required.” It welcomed the removal of the protection statements and the average discount tables, and then went further than the CMA. The proposal leaves the annual compliance statement in place for insurers and brokers alike, and BIBA says the two sets of submissions are substantially identical. It asked the CMA to review the definition of a private motor insurance provider so that brokers fall out of that duty, writing: “Insurance brokers distribute private motor insurance products. They do not design the products, determine the pricing structure, set the terms and conditions, or establish the operation of NCB protection.” BIBA also pointed to the Chancellor’s stated wish to cut the cost of regulation by 25%.

For a driver, the BIBA request changes little at the counter. It concerns paperwork sent to the CMA each year. The disclosure the driver sees sits in Part 2. The four responses that backed removing it came from the Association of British Insurers, two insurers and a broker, and the one response that backed keeping it came from the AA.

What protects you if the CMA goes ahead

The proposed variation order in Appendix D is short. It omits Part 2, Schedules 1a and 2, Annex 1 of Schedule 3, the second paragraph of Schedule 3 that lists the average discounts, and Article 6.1(b). Part 3, which bans wide most favoured nation clauses between insurers and comparison sites, falls outside this review and stays. The rest of Part 4 stays too.

Other rules keep applying. Arthur J Gallagher pointed the CMA to the FCA’s insurance conduct rules on optional add-ons, which the firm said require appropriate pre-contract information “in good time and on a comprehensible way”, active election of optional add-ons, and communications that are clear, fair and not misleading. That reading is the firm’s, as recorded by the CMA, and the Duty sits on top. The CMA also noted that the Digital Markets, Competition and Consumers Act 2024 lets it enforce certain consumer protection laws directly, with directions, monetary penalties and redress for consumers, and that its price transparency guidance (CMA209) tells insurers how to quote prices.

The difference is who writes the words. Today the CMA order supplies the sentences and the tables. If the order is varied, each insurer and comparison site decides how to explain protection, under the FCA Consumer Duty and the CMA’s consumer powers. Drivers who think a firm explained protection badly can complain, and the guide to motor insurance complaints sets out the route from the insurer to the Financial Ombudsman Service.

What to check when you buy protection

The CMA expects to decide this month. The questions that the 2015 statement answers today are worth asking whether or not the statement survives.

First, ask how many claims the protection allows before the number of no claims years drops. Second, find out what it adds to the premium in pounds, and compare that with the discount it protects. Third, check what a fault claim, or a non fault accident, does to the renewal price. The old wording says plainly that protection does not shield the overall price of the policy, and that holds as a fact about how the product works whatever the CMA decides.

The step back mechanics are set out in more detail in the guide to fault claims and your discount.

For the wider premium figures, the Confused.com index shows how insurance fell this year in most regions while Northern Ireland jumped by £209. The CMA case page for its review of market remedies will carry the November decision when it lands.

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