$16.8 million in criminal fines. 

A $750,000 civil penalty. 

More than 570,000 allegedly misleading renewal documents.

And now, an Australian Securities and Investments Commission (ASIC) review finding significant gaps in how insurers explain premium changes to customers. Recent regulatory action has examined information on insurance websites, Product Disclosure Statements (PDS), and renewal communications.

The circumstances are different, and the financial consequences shouldn't be directly compared. But there is a common thread:

Can customers rely on the information an insurer gives them to accurately understand their cover, their rights and what they are paying? That question is becoming increasingly important.

$16.8 million: the headline benefit must match the actual cover

In February 2025, the NSW Supreme Court convicted Allianz Australia Insurance Limited and AWP Australia Pty Ltd and imposed criminal fines totalling $16.8 million for making false or misleading statements. (asic.gov.au). Allianz was fined $13.5 million and AWP $3.3 million.

The case concerned information published online about domestic and international travel insurance. The Court found that Allianz and AWP misrepresented characteristics or levels of travel insurance coverage. In some instances, Allianz's website advertised maximum benefits payable to customers without stating that sub-limits, terms, conditions or exclusions would restrict those benefits.

The issue wasn't simply whether individual words were technically correct. It was whether the information presented to consumers accurately represented the cover they could actually receive.

In reporting the judgment, ASIC highlighted Justice Rothman's comments “…it is important that corporations take the steps at the highest level to ensure that proper processes are in place which prevent breaches of this kind…”

For insurers managing large portfolios of products and regulated communications, that raises an important question:

How do you verify that every benefit communicated to a customer remains consistent with the exclusions, sub-limits, conditions and policy rules underneath it?

A change to a policy condition can have consequences across PDSs, websites and other customer communications. If those documents are managed independently, inconsistency becomes considerably harder to control.

$750,000: customers need to be able to rely on the PDS

Product Disclosure Statements (PDSs) are designed to help consumers understand what they're buying.

The HCF Life case demonstrates why the accuracy of the information within them matters. 

In May 2025, the Federal Court ordered HCF Life Insurance Company to pay a $750,000 penalty following an earlier finding that a pre-existing condition term in certain HCF Life policies was liable to mislead the public. (asic.gov.au)

The Court found that the term could suggest HCF Life had a broader ability to deny coverage for pre-existing conditions than the law actually permitted. HCF Life was also required to make correct disclosures. As ASIC reported, the Court recognised that consumers are entitled to regard PDSs as reliable documents containing accurate and sufficient information about when benefits will be payable.

That is an important standard. An insurance PDS isn't simply a repository for approved wording. It needs to accurately communicate the relationship between policy terms, exclusions, customer rights and the legislation governing them. And those relationships can change.

The matter also continued into 2026. The full Federal Court dismissed ASIC's appeal concerning whether the term was also an unfair contract term, but importantly, that decision did not disturb the earlier finding that the term was liable to mislead the public. (asic.gov.au)

More than 570,000 renewal documents: can customers trust the comparison?

Disclosure risk isn't confined to PDSs. Renewal communications can be just as important to the customer's understanding of what they are paying. In September 2025, ASIC commenced Federal Court proceedings against RACQ Insurance alleging that it had sent more than 570,000 renewal documents containing false or misleading premium comparison information between September 2019 and December 2024.  (asic.gov.au)

ASIC alleges that the "last period premium" shown in renewal documents was, in many cases, higher than the amount customers had actually paid after negotiating discounts or making policy changes.

ASIC argues this could have distorted the apparent size of the customer's premium increase. ASIC provides a striking example. One renewal document showed a previous premium of $6,930.55 and a new premium of $7,033.57 - suggesting an increase of around 1.5%.

According to ASIC, the customer had actually paid $5,024.18, meaning the proposed renewal represented an increase of around 40%. The allegations have not been finally determined by the Court. But the case raises an important disclosure issue.

Information can be numerically precise and still create a misleading impression if the number being used doesn't accurately represent the customer's position. There is also a governance dimension. ASIC alleges RACQ began receiving customer complaints about the issue two days after the practice commenced, but that the potential issue wasn't escalated to relevant internal committees until November 2024.

In 2026, ASIC widened the lens

ASIC's latest review suggests insurers should think more broadly. In August 2026, ASIC published Report 838: Road testing transparency in car insurance premiums. (asic.gov.au)

The regulator examined disclosure practices across eight brands operated by five general insurers, representing around 72% of the motor insurance market, alongside consumer research involving more than 2,000 Australians. Its findings were significant. 

ASIC found none of the insurers reviewed explained in quote and renewal documents the key factors affecting how premiums were calculated or why those factors had changed from the previous year.

ASIC also found that where insurers charged more for paying by instalments, renewal notices did not clearly explain that customers could potentially save up to 20% by paying annually. 54% of consumers surveyed either didn't know about the additional cost or had missed the information. And 73% of consumers recalled receiving only generic reasons for premium increases.

ASIC is now calling on insurers to improve quote and renewal documents by:

  • explaining the key factors affecting a customer's premium and why it changed;
  • showing how excess, cover options and payment methods affect price;
  • clearly showing the total cost of paying by instalments and the dollar difference compared with annual payment;
  • comparing important policy changes such as excess and insured value year-on-year; and
  • making important information prominent and easier to find at renewal.

ASIC has also made its enforcement position explicit: it says it will take action where insurance premium disclosures are inaccurate or misleading.

That makes disclosure governance a current industry issue, not simply a lesson from historical enforcement cases.

The insurance disclosure challenge is getting bigger

Put these developments together, and a pattern emerges:

  • Allianz/AWP: Did advertised benefits accurately reflect the limitations on cover?
  • HCF Life: Did the PDS accurately explain when the insurer could deny a claim?
  • RACQ: Did renewal information accurately show customers how their premium had changed?
  • ASIC Report 838: Are quote and renewal documents giving consumers enough useful information to understand why premiums are changing?

Different documents. Different regulatory issues. But the same fundamental challenge:

Does the information provided to the customer accurately reflect the product, policy and price underneath it?

For insurers with multiple products, brands and distribution channels, maintaining that alignment isn't simple.

One product change can affect a PDS, policy wording, insurance guide, website, renewal communication and other customer-facing content. One pricing change can affect information across thousands, or millions, of communications. One change to an exclusion or benefit can require corresponding changes in multiple places.

The challenge isn't simply making the change. It's knowing everywhere the change needs to be made, ensuring it is made consistently, and proving that the resulting disclosure was properly reviewed and approved.

Can you substantiate what you're telling the customer?

Recent regulatory action raises some practical questions for insurance disclosure teams.

When a material statement appears in a PDS or other regulated communication:

  • Where did that information originate?
  • What evidence, policy term or business rule supports it?
  • Are limitations and exclusions reflected accurately?
  • Who verified the statement?
  • Who approved it?
  • Where else does the same information appear?
  • What happens to those documents when the underlying product changes?
  • Does a change invalidate an earlier approval?
  • Can customer complaints trigger a review?
  • Can you reconstruct the evidence trail years later?

These aren't findings ASIC has made in every matter discussed above. They are governance questions that the direction of regulatory scrutiny makes increasingly difficult to ignore.

And for organisations still managing disclosure through combinations of Word documents, PDF mark-ups, spreadsheets, email approvals, Teams messages and shared drives, answering them can require considerable manual effort.

From producing disclosure to governing it

Insurers need to be able to connect source information → content → verification → approval → publication.

When information changes, they need to understand which documents are affected. When wording is approved, they need evidence of what was reviewed and by whom. And when a regulator challenges a disclosure years later, they need to be able to reconstruct the decision without piecing together emails, spreadsheets and historic document versions.

That is the shift from document production to defensible disclosure.

Building defensible insurance disclosure with Objective Keystone

Technology cannot determine whether an insurance product is appropriate or replace the judgement and accountability of Product, Legal, Compliance, Risk and other subject-matter experts. But it can provide a more controlled environment for how regulated information is created, reviewed, verified, approved and published.

Objective Keystone helps insurers manage complex regulated documents through a centralised disclosure-production and governance process. Trusted by over 35 financial services organisations to manage their disclosure management process, including one of Australia’s leading general insurers.

Instead of relying on disconnected Word documents, spreadsheets, shared drives, email or Teams trails, organisations can establish structured review and approval workflows, maintain version histories, manage reusable content and create an auditable record around the production of regulated documents.

The objective isn't simply faster insurance document production. It's being able to answer a much more important question:

Can you stand behind every material statement you publish?

Because as ASIC's recent enforcement and industry review demonstrate, disclosure isn't just about giving customers information.

It's about making sure they can rely on it.

If you’re ready to create a more defensible governance process, get in touch.

The regulatory matters referenced in this article are provided for general informational purposes. Allegations in ongoing proceedings, including those concerning RACQ, have not been finally determined by the Court. Monetary figures represent different categories of regulatory outcomes and should not be interpreted as directly comparable measures of misconduct, customer loss or regulatory severity.