Replacement business: what PPR rule 19 asks of your brokerage
Rule 19 puts a 14-day paper loop between two insurers whenever a risk policy is replaced. What counts as a replacement, and what the record has to show.
Average cuts a claim in proportion to the shortfall. How Southern African brokers run a yearly sum-insured check on WhatsApp and record what the client answers.
The assessor agreed the fire damage came to R500 000. The insurer paid R300 000. Nobody declined anything, nobody alleged non-disclosure, and the policy was in force and paid up. The building was simply insured for R1 800 000 when it would have cost R3 000 000 to rebuild, and the average condition did the rest.
That phone call is one of the worst a broker takes, because there is no argument to win. The client is not owed the balance. What they are owed — and what a complaint to the ombud will test — is evidence that somebody asked them, in terms they understood, whether the sum insured was still right.
Most short-term wordings in the South African market carry a condition of average, sometimes called proportional settlement. If the sum insured is less than the value of the property at the time of the loss, the insurer settles in the same proportion. It applies to partial losses, which is the part clients never expect: they assume a R500 000 claim under a R1 800 000 policy is comfortably covered.
| Replacement value at the date of loss | Sum insured | Proportion insured | Loss | Settlement before excess |
|---|---|---|---|---|
| R3 000 000 | R3 000 000 | 100% | R500 000 | R500 000 |
| R3 000 000 | R2 250 000 | 75% | R500 000 | R375 000 |
| R3 000 000 | R1 800 000 | 60% | R500 000 | R300 000 |
| R3 000 000 | R1 200 000 | 40% | R500 000 | R200 000 |
Two things follow. First, the shortfall is silent: nothing in the monthly premium tells the client anything is wrong, and the policy looks perfectly healthy right up to the loss. Second, the gap grows on its own. Building costs, contents and business assets move with inflation and with what the client has bought since inception, while the sum insured sits where it was set — often at a number picked years ago because it produced an affordable premium. Wordings elsewhere in the region borrow heavily from the South African market, so check whether the same condition appears in your Namibian, Botswanan or Zimbabwean schedules rather than assuming either way.
The exposure is rarely spread evenly. In practice it concentrates in a handful of places:
Motor works differently and is worth separating in your own head before you explain it. A motor claim is normally settled on the value basis in the schedule — retail, market or trade — rather than reduced by average, so the conversation there is about which basis the client is on and whether they understand it. Sasria cover, by contrast, follows the sums insured on the underlying policy, so an underinsured building carries the same shortfall into a riot or strike loss; our Sasria renewal checklist for commercial brokers covers the rest of that check.
Under the Policyholder Protection Rules made under the Short-term Insurance Act, an insurer must give the policyholder notice at least 31 days before the renewal date, setting out the premium payable on renewal, the premium last paid so the client can compare, and any change to terms or conditions with an explanation of what it means.
That notice tells the client what the cover will cost. It does not tell them whether the cover is still the right size — no rule requires the insurer to ask, and the client will not volunteer it. The 31 days are, in effect, a standing calendar of prompts across your book: every week, a batch of clients is being told their price, which is the one moment in the year they are actually thinking about the policy. A brokerage that treats that window as a review window rather than a billing window is doing the job commission is paid for.
Long review letters do not get read. A short, specific question on the channel the client already uses does. A workable cadence for a personal-lines or small commercial book:
This is the annual version of the review described in our cover review at policy anniversary use case, and the policy anniversary cover review template gives you wording to adapt. In ORIS, the mechanics are a segment built on the renewal window, a campaign sent from an approved utility template, replies classified as they arrive, and a coverage-gap flag raised on the clients who answer yes — visible in Opportunities & Risks with the rest of the follow-up list. What ORIS will not do is change the policy: it exports CSV, and a person still has to raise the endorsement in your administration system.
Some clients will decline the increase. That is their right, and it is survivable for you — provided the file shows what you told them. Record the replacement value you discussed or the basis you used, the premium impact of correcting the sum insured, the client's decision in their own words, and the date. A WhatsApp thread does that well, because it is timestamped, attributable and in the client's language, but only if it lives somewhere the brokerage controls rather than on a departing adviser's handset; our guide to FAIS record-keeping for WhatsApp conversations sets out how long to keep it and in what form.
That record is also what you will be asked for if the client later complains. The National Financial Ombud Scheme's non-life division sees a steady stream of disputes where the settlement was correctly calculated and the client simply did not know average existed. If the file shows a plain-language explanation and an informed refusal, the brokerage is in a very different position from one that can only produce a renewal invoice; the same principle runs through our note on claim complaints and the records to keep.
No. It is a condition in the wording, so it applies where the wording says it does — typically buildings, household contents, business assets, stock and some all-risks sections. Some products waive it, and some apply it only above a stated tolerance. Read the schedule and the section wording for each client rather than assuming a house rule across your book.
The sum insured is the policyholder's declaration. The broker's exposure is not the number itself but the advice around it: whether the basis was explained, whether the question was asked at inception and at review, and whether the answer was recorded. That is why an informed refusal in writing matters more than being right about the value.
No, and suggesting it for every household would be disproportionate. For homes and contents, the insurer's own calculators and current rebuild-cost guidance are usually enough to start a sensible conversation. For commercial buildings, plant and high-value specified items, a professional valuation is the safer route, and the cost is small against the shortfall it prevents.
Not unilaterally. You can propose an increase, explain the premium effect and act on the client's instruction, but changing a client's declared value without their agreement creates a different problem. Send the proposal, keep the answer, and endorse on the strength of it.
Treat silence as an open item, not as consent. Follow up once by another route, note the attempts on the file, and flag the account for the next renewal cycle. A documented attempt to review is worth a great deal more at complaint stage than a book where nobody asked at all.
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