Analysis Report: Complaint Inquiry to Insurance Providers 2023

ANALYSIS REPORT Complaint Inquiry to Insurance Providers

In brief In 2024, the AFM conducted its sixth annual inquiry into registered complaints among all insurance providers. The inquiry yields relevant information that benefits both our supervision and market participants. We also shared the (aggregated) data with the European Insurance and Occupational Pensions Authority (EIOPA) for their annual Consumer Trends Report. Through this report, the AFM links a number of insights from the provided data back to insurance providers.

The inquiry requested information on all complaints registered with insurance providers in 2023 (including complaints that were still open from before 2023). This report shares the key statistics from the AFM. The complaint inquiry forms an important source for the AFM's data-driven supervision. Based on the information obtained, the AFM will engage in dialogue with the sector. Furthermore, the AFM hopes that the sector can benefit from the aggregated insights in this report.

Total 133,000 complaints In total, 149 insurance providers reported completing 133,000 complaints. This is a decrease of 2.2% compared to the previous year, when 136,000 complaints were reported (see Figure 1).

Figure 1. Total number of complaints per year Source: AFM

Complaints by sub-market As in the previous year, the largest portion, almost half, of the total number of complaints (62,700 complaints) comes from the Health sub-market (see Figure 2). This sub-market is also the largest in terms of number of policies and premium volume. This is followed by the Damage (53,900 complaints) and Life (16,300 complaints) sub-markets.

Figure 2. Total number of complaints by sub-market in 2023 Source: AFM

Development of number of complaints per sub-market Whereas last year an increase in the number of complaints was visible for every sub-market in 2022, in 2023 we only see an increase in the Life sub-market (12.4%). For the other two sub-markets, Damage and Health, we see that the total number of complaints has decreased. The number of complaints in the Damage sub-market decreased by 7.8% and the number of complaints in the Health sub-market decreased by 0.5%. See Figure 3 for this.

Figure 3. Development of number of complaints per sub-market Source: AFM

Number of complaints regarding Life products increased Figure 4 shows a breakdown of the number of complaints per product group for the Life sub-market. Here we see a decrease in the number of complaints for 'Death Risk Insurance' and 'Other Life Insurance'. However, for the other product groups within the Life sub-market, the number of complaints actually increased.

We see the largest increase in the number of complaints for the product groups 'Life Investing', namely an increase of 24.4%, and for 'Funeral Insurance' with an increase of 20.7%. The requested data does not provide insight into the concrete causes of the increase in the number of complaints in a certain product group. However, the AFM will engage in dialogue with the market or individual insurers in light of striking trends.

Figure 4. Development of number of complaints per product group - Life Source: AFM

Number of complaints regarding Damage insurance decreases Figure 5 shows a breakdown of the number of complaints per product group for the Damage sub-market. This shows that the number of complaints in almost all product groups within the Damage sub-market has decreased, except for the product groups 'Legal Aid Insurance (+13%)' and 'Liability Insurance (+10%)'. We see the largest decreases in the number of complaints for 'Other Damage Insurance (-17.2%)' and 'Motor Vehicle Insurance (-11.8%)'.

Figure 5. Development of number of complaints per product group - Damage Source: AFM

Number of complaints regarding Health insurance Figure 6 shows a breakdown of the number of complaints per product group for the Health sub-market. This shows that in 2023 the number of complaints for basic health insurance increased slightly and for supplementary insurance decreased.

Figure 6. Development of number of complaints per product group - Health Source: AFM

Complaints highest in the management phase and in the claims handling phase Figure 7 shows the completed breakdown of the number of complaints per service delivery phase in which the complaint arose, per market segment. This shows that for the Damage and Health sub-markets, the highest number of complaints falls into the category 'Claims Handling Payout'. The category 'Claims Handling Payout' refers to complaints that can arise during the handling of damage claims, for example regarding the amount of the payout because the coverage was changed during the term and the customer was not aware of this, or the manner in which the damage claim is handled.

For the Life sub-market, most complaints relate to 'Service Delivery Management Phase'. These are complaints that arose during the term of the insurance. This could include, for example, complaints about errors in changing a beneficiary or complaints about the annual policy value statement.

Figure 7. Number of complaints per sub-market divided by complaint cause Source: AFM

The average duration of a complaint has decreased slightly Finally, it is notable that the average duration of a complaint has decreased slightly from 23.5 days in 2022 to 23.1 days in 2023. The duration starts at the moment a consumer submits the complaint and ends when the complaint is handled. A complaint is considered handled when there is no longer a complaint/expression of dissatisfaction. Figure 8 provides an overview of the average duration over the past three years.

Figure 8. Duration of complaints per year in days Source: AFM

Figure 9 shows that the duration (as in 2022) is longest for the product group 'Life Investing' and shortest for 'Travel Insurance'. A long duration can be a reason for the AFM to engage in dialogue with the market or individual insurers about this.

Figure 9. Duration of complaints in days per product group Source: AFM

Data Quality For the AFM, it is of great importance that the quality of the reported data is good. In this context, the AFM checks, among other things, whether ongoing complaints from the previous year are reported under the same complaint number. The AFM also checks whether all closed complaints have an end date and whether no negative duration is reported. In case of inaccuracies, the AFM asks providers to correct the complaint data and resubmit it. This is also the case if providers report 'zero' complaints and do not substantiate this figure; providers are then asked to provide further substantiation. Next year, the AFM will also pay attention to data quality and specifically focus on the points mentioned above.

Expansion of Product Categories Based on new insights and experiences, the AFM reviews annually whether the design of the complaint inquiry can be improved. If necessary, the AFM adapts the inquiry accordingly. In that case, insurers are informed well in advance of the sending of the information request about the adjustment(s) made.

For the next complaint inquiry, which will take place in 2025, the list of product categories will be adjusted/expanded. This adjustment includes, among other things, that i) product categories will be added and ii) the name of some product categories will change. Insurers were informed about this change in July 2024.

The complaint inquiry is held annually, allowing the AFM to show global trends and developments based on this. The data from the 2023 complaint inquiry helps us to shape our supervision more efficiently and effectively.

More Information In the annual complaint inquiry, we request information on ongoing, received, and closed complaints per year. The complaint inquiry is conducted among insurance providers in the Netherlands. The requested information includes, among other things, duration, type of product, type of customer, and the main cause of complaints. The structure of the inquiry is granular, meaning that the provider reports per complaint. On our website, there is more general information about the complaint inquiry, such as about the design, the method of reporting, and the definitions used.