Complaint Survey 2025: Insurance Providers' Complaints for 2024 — AFM — NL

COMPLAINT SURVEY 2025 Complaint Survey of Insurance Providers for 2024

In brief – In 2025, the AFM conducted its seventh annual survey of registered complaints among all insurance providers. The survey contains a wealth of 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 feeds back certain insights from the provided data to insurance providers.

SEPTEMBER | 2025

The survey requested information on all complaints registered with insurance providers in 2024 (including complaints that were still open from before 2024). In this report, the AFM shares the most important statistics. This is the seventh year in which we have systematically surveyed complaints from insurance providers. The requested data does not provide insight into the precise causes of the developments depicted in the insurance market. However, the AFM engages in discussions with the market regarding notable trends. The information from the annual survey of registered complaints among all insurance providers is of great importance for the AFM's supervision. The AFM uses this information, for example, in prioritizing projects. In recent years, the AFM has discussed various developments and signals with the insurance sector.

Total 125,000 Complaints

In total, 173 insurance providers in the Netherlands reported a total of 125,000 complaints. This is a decrease of 6% compared to last year, when 133,000 complaints were reported (see Figure 1). The AFM notes that the number of complaints has been slowly decreasing annually since 2022.

Figure 1. Total number of complaints per year

Source: AFM 160000 169000 154000 125000 136000 133000 125000 0 20000 40000 60000 80000 100000 120000 140000 160000 180000 2018 2019 2020 2021 2022 2023 2024

As in previous years, the largest share, nearly half, of the complaints (58,900) 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. Following this, as in previous years, are the Property sub-market (51,100 complaints) and Life sub-market (15,100 complaints).

Figure 2. Total number of complaints per sub-market Source: AFM 15100 51100 58900 0 10000 20000 30000 40000 50000 60000 70000 Life Property Health

Whereas in 2023 only the Life sub-market showed an increase (12.4%) and the other two sub-markets, Property and Health, showed a decrease in the total number of complaints, in 2024 a decrease in the number of complaints is visible across all sub-markets. The largest decrease is seen in the Life sub-market with 7.4%, followed by a decrease of 6.1% in the Health sub-market and finally a decrease of 5.2% in the Property sub-market compared to 2023. See Figure 3 for this.

Figure 3. Development of complaint numbers per sub-market Source: AFM 58900 62700 63000 62500 69000 86000 51100 53900 58500 49000 55000 57000 15100 16300 14500 13500 30000 26000 0 10000 20000 30000 40000 50000 60000 70000 80000 90000 100000 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 Health Property Life

Figure 4 shows a breakdown of complaints by product group for the Life sub-market. Notably, the product group "Life - other" has decreased significantly. This is because insurers are registering their complaints better in the applicable product group for the Life sub-market. Besides this decrease, there are two increases in complaints: Annuities with an increase of 28.7% and the product group Life-saving with an increase of 20.8%.

Figure 4. Development of complaint numbers per product group - Life

Source: AFM 220 2080 2620 530 700 2200 930 890 930 900 1200 1100 1660 1290 1120 1700 1800 1800 3890 3220 2750 2700 3000 4500 5160 5660 4540 5200 6300 8000 3250 3140 2590 2500 16900 8100 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 Life - other Death Benefit Annuities Life-saving Life-investment Funeral

Figure 5 shows a breakdown of complaints by product group for the Property sub-market. This shows that the number of complaints in 2024 decreased for almost all product groups within the Property insurance sub-market compared to 2023. The largest decreases in complaints are Fire & Business with 24.0% and Property other with 7.4%. Legal assistance insurance, however, increased by 2.5%. Data is only available for 2024 for the two new product groups Gadget and Cyber insurance.

Figure 5. Development of complaint numbers per product group - Property

Source: AFM 2090 2200 2000 1900 2400 2500 10180 13400 14800 11300 12400 13100 3 1550 1930 2000 2000 1800 2300 3000 15010 14900 16900 12700 13600 14300 5330 5200 4600 4400 4900 4300 5690 6000 6200 4400 7400 6600 9350 10100 12200 11300 12100 13000 0 2000 4000 6000 8000 10000 12000 14000 16000 18000 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 Liability Fire & Business Cyber Gadget Income Motor Vehicles Legal Assistance Travel Property other

Figure 6 shows a breakdown of complaints by product group for the Health sub-market. This shows that in 2024 the number of complaints for both basic health insurance and supplementary insurance decreased by 5.7% and 8.1% respectively. It can be seen that the number of complaints for supplementary health insurance is decreasing over the years, while the number of complaints for basic health insurance appears to be stabilizing.

Figure 6. Development of complaint numbers per product group - Health Source: AFM 12400 13500 15700 14800 18600 25000 46400 49200 47700 47700 50800 61400 0 10000 20000 30000 40000 50000 60000 70000 2024 2023 2022 2021 2020 2019 2024 2023 2022 2021 2020 2019 Health supplementary Health basic

Figure 7 shows the completed breakdown of complaints by service delivery phase for each market segment. This shows that for the Property and Health sub-markets, the highest number of complaints falls into the category 'Claims Handling Payout'. Complaints in the category 'Claims Handling Payout' are various complaints that can arise during the handling of damage claims. For example, regarding the amount of the payout, because coverage is changed during the term and the customer was not aware of this. Or complaints about the manner in which the damage is handled.

For the Life sub-market, most complaints fall into the 'Service Delivery Management Phase'. These are complaints about the level of service that arise during the term of (in this case) life policies. These are, for example, complaints about the reachability of the insurer, or the failure to respond or late response to a request for a policy value overview.

Figure 7. Number of complaints per sub-market divided by complaint cause Source: AFM 690 28530 24240 710 4680 2700 24500 18590 3130 2200 120 3710 10070 140 1090 0 5000 10000 15000 20000 25000 30000 Employee Claims Handling Payout Service Delivery Management Phase Acceptance Intermediation - Advisory Employee Claims Handling Payout Service Delivery Management Phase Acceptance Intermediation - Advisory Employee Claims Handling Payout Service Delivery Management Phase Acceptance Intermediation - Advisory Health Property Life

Finally, it is noted that the average duration of a complaint – viewed across all complaints – is 19.4 days. This duration has increased slightly compared to last year (16.8 days). The number of days is calculated from the moment a consumer submits the complaint until it 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 6 years. Figure 9 shows that the duration is longest for the product group 'Annuities' (30 days) and shortest for the product group 'Gadget', 7 days. The product group 'Gadget' includes phone insurance.

Figure 8. Duration of complaints per year Source: AFM

Figure 9. Duration of complaints in days per product group Source: AFM 19,4 17 17,4 14,7 28,6 13,4 0 5 10 15 20 25 30 35 2024 2023 2022 2021 2020 2019 7 8 11 11 12 12 13 15 16 18 19 20 29 30 0 5 10 15 20 25 30 35 Gadget Travel Legal Assistance Motor Vehicles Health - basic Funeral Property other Health - supplementary Fire & Business Life other Liability Life-saving Death Benefit Income Life-investment Annuities

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. It is also checked whether all closed complaints have an end date and whether no negative duration is reported. In case of inaccuracies, the AFM has requested providers to correct the complaint data and resubmit it. Next year, the AFM will continue to pay attention to data quality. The same applies to the missing substantiation from providers who report 'zero' complaints.

Expansion of Product Categories

Based on new insights and experiences, the AFM improves the complaint survey where necessary on an annual basis. Therefore, the AFM will expand certain product categories of Life products. The AFM will inform insurers of this expansion well in advance, so they can prepare for the upcoming complaint survey for 2025. The complaint survey is held annually, allowing the AFM to show global trends and developments based on this.

More Information

In the annual complaint survey, we request information on ongoing, received, and closed complaints per year. The complaint survey is conducted among all insurance providers with a Dutch license and the largest foreign providers active in the Netherlands. The requested information includes, among other things, duration, product type, customer type, and the main cause of complaints. The structure of the survey is granular, meaning the provider reports per complaint. More general information about the complaint survey, such as the design, reporting method, and definitions used, is available on our website.

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