Personal-lines renewals: what ICOBS 6.5 makes you disclose, and how to keep the client anyway

Contents

1. What the renewal notice must contain
2. The price-walking ban, and the part that applies to intermediaries
3. Auto-renewal: the rule that reaches your WhatsApp number
4. Retention when the price is the price
5. Where ORIS fits
6. Frequently asked questions

British personal-lines renewal is now a regulated act of transparency. The firm must show the client last year's price next to this year's, tell them they can compare the market, and — after four renewals — say in so many words that shopping around might get them a better deal. A generation of retention tactics was built on the client not noticing the increase. Those tactics are gone, and the firms that have adapted are the ones that stopped treating the renewal notice as a sales document and started treating it as the last step of a conversation that began months earlier.

What the renewal notice must contain

ICOBS 6.5.1R applies where a firm proposes to renew a general insurance contract for a consumer and the policy runs for ten months or more; group policies are outside it. Six things have to be in the notice.

What must be disclosed	The detail that catches firms out
The renewal premium	The amount actually payable, not an indicative figure
The previous premium	The premium at inception of the expiring policy; where mid-term changes occurred, an annualised equivalent excluding mid-term adjustment fees
A prompt to check the cover	The client must be told to check that the level of cover offered on renewal is still appropriate for their needs
A statement that they may compare	They can compare price and cover with alternative providers if they wish
Whether the policy auto-renews	Or whether the client must act to accept the offer — stated, not implied
The long-tenure wording, from the fourth renewal	"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."

Two conditions govern how it goes out: in good time before renewal, and in writing or another durable medium, presented clearly and accurately with the client's attention drawn to the key information. That is the boundary a messaging channel must respect. A WhatsApp message can tell the client the renewal pack is ready, can answer questions about it and can carry the instruction back — but the disclosure itself belongs on a durable medium. Firms that try to compress the six items into a phone-screen template usually breach the "clearly and accurately" limb while technically covering the list.

The price-walking ban, and the part that applies to intermediaries

For home and motor, ICOBS 6B sets the pricing rule: a firm must not set a renewal price higher than the equivalent new business price (ICOBS 6B.2.1R). Brokers sometimes read this as an insurer problem. It is not. ICOBS 6B.2.34R reaches intermediaries involved in setting the price: the portion the intermediary sets, or contributes, must be no higher than it would be for a new business customer. Commission the firm would forgo to win new business, and cash incentives offered to new customers, have to be reflected in the renewal price too. Where a package combines home and motor, each element and the bundled price must comply separately.

There is a record-keeping tail as well. Firms must keep written records showing how they satisfy themselves that they do not systematically discriminate on tenure, and how they resolved any ambiguity in reaching that conclusion; senior managers attest annually to compliance with ICOBS 6B. The FCA's evaluation of the pricing remedies, published as EP25/2, is worth reading before anyone in the firm assumes the rules have settled into background noise.

The strategic point for a brokerage is simple and uncomfortable: loyalty can no longer be monetised, so it has to be earned. The client who stays is now, by rule, paying what a stranger would pay. Everything that makes them stay has to be non-price.

Auto-renewal: the rule that reaches your WhatsApp number

ICOBS 6A.6 requires a firm to give consumers easy and accessible ways to cancel the auto-renewal feature, and specifies that those methods must include at least all the methods by which a consumer can buy a new policy from the firm. Read that against a brokerage that sells over WhatsApp. If a client can take out a policy by messaging you, they must be able to switch off auto-renewal by messaging you. A firm that quotes and binds on the channel but insists on a signed letter to stop auto-renewal has the asymmetry the rule was written to remove.

In practice this means the cancellation route has to be as monitored as the sales route: a request arriving on a Saturday cannot sit unread until Tuesday, and the acknowledgement has to be recorded against the client. It also means the firm should stop treating an auto-renewal cancellation as a save opportunity to be slowed down. Acknowledge it, act on it, and then — separately and only if appropriate — ask whether the cover still suits them.

Retention when the price is the price

If the number in the notice is now fixed by rule, retention has to be built before the notice arrives. A workable personal-lines cadence looks like this:

1. Renewal minus 45 to 60 days — the check-in. A short, specific message asking whether anything changed: mileage, an extension, a new driver, a phone or bike worth adding. This is servicing, so it sits on the service side of consent, and it produces the information that makes the renewal accurate.
2. Renewal minus 30 — the recommendation. If the check-in surfaced something, remarket or adjust now, while there is time. If nothing changed, say so explicitly; "we checked and your cover is still right" is a service the client cannot get from a price comparison site.
3. Renewal minus 21 — the notice itself, on durable medium, with the six disclosures and no promotional content wrapped around it.
4. Renewal minus 14 — the availability message. One line confirming the pack arrived and offering to talk it through. Increases are survivable when explained; they are fatal when discovered.
5. Renewal minus 5 — the instruction reminder, stating plainly what happens if the client does nothing, which depends on whether the policy auto-renews.
6. Renewal plus 7 — the confirmation and the ask. Confirm cover is in force, and only here, with consent, raise anything additional.

Two of those steps are new work; the rest is work the firm was doing anyway, just moved earlier. The full step-by-step version is set out in the policy renewal use case, the wording for the notice message in the renewal notice template, and the year-round version of the same logic in our piece on an annual review cadence for personal lines. Commercial accounts run on a different clock and mostly outside ICOBS 6.5 — that sequence is in the 60-day commercial renewals playbook.

What to measure: the proportion of renewals where a check-in happened before the notice went out; retention split between checked and unchecked cohorts; and how many clients contacted the firm after the notice rather than after the debit. The last one is the honest indicator of whether the disclosure was actually clear.

Where ORIS fits

The cadence above is arithmetic across a book of a few thousand policies, and that is where the platform earns its place. Lifecycle triggers watch renewal dates and prepare the cohort for each stage a set number of days ahead; segments filter on renewal window so the minus-45 check-in leaves at minus 45; campaigns go out from Meta-approved templates tagged as service or marketing to match the consent held. Replies land in a shared inbox against the client record, so the "we're putting a caravan on the drive" answer is attached to the policy rather than sitting on one handler's phone, and engagement and risk scores show which households have gone quiet before the renewal proves it. ORIS does not produce the renewal documentation and does not connect to a broker management system — the notice stays where it is produced today, and data moves by CSV export. What it changes is that the conversation around the notice happens at all, on time, and is recorded.

Frequently asked questions

Does ICOBS 6.5 apply to a policy the client bought through us but the insurer renews?

The disclosure obligation attaches to the firm proposing the renewal, so where the insurer issues the renewal invitation it carries the requirement. Brokers should still confirm what the client receives and when, because the client will hold the broker responsible for anything that reads unfairly, and the Consumer Duty's support outcome applies to the firm in the distribution chain regardless.

What exactly counts as the previous premium?

The premium the consumer paid at the start of the expiring policy. If there were mid-term changes, the figure is an annualised amount reflecting them, excluding fees charged for making those adjustments. It is not the total the client paid over the year, and it is not the original quote if the policy was subsequently adjusted.

Can we deliver the renewal notice by WhatsApp?

The notice must be in writing or another durable medium, which a WhatsApp message is not reliably: the content can be deleted, media expire and the client cannot store and reproduce it unchanged. Use the channel to tell the client the pack is available and to answer questions on it, and deliver the notice itself the way you deliver other contractual documents.

Does the price-walking ban apply to commercial policies?

No. ICOBS 6B is limited to home and motor insurance pricing for consumers. Commercial renewals fall outside it, though the customer's best interests rule and, for most SME clients, the Consumer Duty still shape what a fair renewal price and process look like.

A client wants to cancel auto-renewal by WhatsApp. Must we accept that?

If a consumer can buy a new policy from the firm through that channel, ICOBS 6A.6 requires the cancellation route to include it. The safer operational answer is to accept the request on whatever channel it arrives, confirm it in writing, and record it against the client — rather than routing the client to a slower method than the one that sold them the policy.

Is a premium increase on renewal now a compliance risk in itself?

Not by itself. What ICOBS 6B prohibits is charging a renewing customer more than the equivalent new business price; genuine changes in risk, claims experience or insurer rating still move prices. The risk is an increase that cannot be explained, or one the client only discovers when the money leaves their account.