PA&H — References | Risk Code Hub

UK Legislation & Regulation

1.
Insurance Act 2015 — Fair presentation duty for commercial insurance. Replaces utmost good faith avoidance remedy with proportionate remedies. Applies to group A&H (KA/KG). VER legislation.gov.uk
2.
Consumer Insurance (Disclosure and Representations) Act 2012 — Retail/personal insurance non-disclosure rules. Applies to KA individual PA, KT travel. Duty to take reasonable care not to misrepresent. VER legislation.gov.uk
3.
FCA Consumer Duty (PS22/9) — Policy statement July 2022; effective July 2023 (new products) / July 2024 (legacy). Four consumer outcome pillars for retail insurance including all K-series products sold to consumers. VER fca.org.uk
4.
National Insurance Act 1911 — First UK state sickness and unemployment insurance. Historical foundation of modern A&H market structure. VER
5.
Employers' Liability (Compulsory Insurance) Act 1969 — Compulsory EL insurance for UK employers; relevant boundary with group PA/workers' compensation context. VER
6.
Data Protection Act 2018 / UK GDPR — Health data is special category data (Article 9 GDPR). Explicit consent required for processing medical information in underwriting, claims and use of wearable/health device data. VER
7.
Equality Act 2010 — Age and disability as protected characteristics. Actuarial justification required for differential treatment. FCA oversight of mental health exclusion fairness. VER

International Legislation & Conventions

8.
Affordable Care Act (ACA) 2010 — USA health insurance reform. Extended coverage to ~30m uninsured Americans; prohibited PEC exclusions; mandated essential health benefits. Relevant to Lloyd's US health-related products. VER
9.
Maritime Labour Convention (MLC) 2006 — International Labour Organization convention. Mandates crew medical examinations, sickness benefit and repatriation for seafarers. Insurance basis for KM maritime PA obligations. VER ilo.org
10.
Defence Base Act (DBA) 1941 — USA; compulsory workers' compensation for US contractors working overseas on US government contracts. Relevant to KM and KX for US government contractors in conflict zones. VER
11.
COBRA Act 1985 (USA) — Continuation of employer health coverage for terminated employees. Established portable health coverage concept in US employer benefits market. VER

Market & Industry Sources

12.
CMI (Continuous Mortality Investigation) — UK actuarial body providing morbidity and mortality tables used in PA&H pricing. Publishes annual working papers on long-COVID, mental health disability and longevity trends. Authoritative data source for group IP reserving. VER actuaries.org.uk
13.
Swiss Re sigma No. 3/2024 — Accident & Health Insurance — Annual Swiss Re review of global A&H market including GWP, claims trends, long-COVID and medical inflation. Primary source for global A&H market size estimates. EST swissre.com
14.
Munich Re — Topics Health publication — Munich Re's annual review of PA&H market trends, pandemic risk, mental health claims and medical technology impact. Key reinsurer market commentary. EST munichre.com
15.
Association of British Insurers (ABI) — Health & Protection Statistics — Annual UK market data on PMI, group income protection and individual PA GWP and claims. Primary UK market data source. VER abi.org.uk
16.
Lloyd's — Market Intelligence & A&H Thematic Review — Lloyd's periodic reviews of A&H market performance. Market Bulletin Y5311 and related bulletins on pandemic exclusion guidance. EST lloyds.com
17.
FCA — PPI Redress Statistics — Monthly FCA PPI statistics published through to September 2019 showing cumulative £38.3bn in compensation. Definitive figure for PPI mis-selling scale. VER fca.org.uk
18.
International Underwriting Association (IUA) — A&H Committee Publications — IUA market guidance on group A&H, occupational class definitions and treaty reinsurance structures for UK market participants. EST iua.co.uk

Landmark Cases & Regulatory Decisions

19.
Plevin v Paragon Personal Finance Ltd [2014] UKSC 61 — Supreme Court. Undisclosed PPI commission created unfair relationship under Consumer Credit Act 1974. Expanded PPI redress scope to include commission non-disclosure beyond mis-selling. VER
20.
FCA v Arch Insurance (UK) Ltd & Others [2021] UKSC 1 (BI Test Case) — While primarily a property BI case, the Supreme Court's analysis of disease/notifiable disease policy triggers informed subsequent A&H pandemic coverage debates. Confirmed that pandemic-period losses required specific policy trigger language. VER
21.
NHS Waiting Lists — NHS England Statistical Release 2024 — NHS England publishes monthly referral-to-treatment (RTT) waiting time statistics. 7m+ patient waiting list drove record PMI demand in 2023–24. VER england.nhs.uk
22.
NICE — COVID-19 Rapid Guideline: Managing the Long-Term Effects of COVID-19 (NG188) — NICE guideline December 2020 (updated 2021). First formal clinical guidance on long-COVID diagnostic criteria and management. Actuarial significance: established long-COVID as a disabling clinical syndrome. VER nice.org.uk

Confidence Audit by Module

Module	Confidence Level	Key Uncertainties
Overview — Code definitions (KA–KX)	EST	Lloyd's K-series code internal definitions are not publicly published. Definitions are market interpretations consistent with industry knowledge.
Overview — Lloyd's A&H GWP (~£4bn)	EST	Lloyd's does not separately publish A&H GWP breakdown by K-code. Total estimated from market reports.
History — National Insurance Act 1911; NHS 1948; BUPA founding; PPI redress £38bn	VER	Well-documented historical facts from primary sources.
History — Lloyd's A&H market development (inter-war; 1990s treaty growth)	EST	General market development narrative; specific Lloyd's capacity/premium data for historical periods not publicly available.
Timeline — All regulatory events (ACA, FCA Consumer Duty, PPI, NICE NG188)	VER	Verifiable from primary legislative and regulatory sources.
Timeline — 9/11 Lloyd's PA losses; sports disability claims	EST	Lloyd's total PA losses from 9/11 not separately disclosed. Sports disability individual claims reconstructed from public litigation records.
Underwriting — Occupation class definitions, rate loadings, factor tables	ILLUS	Standard industry framework verified; specific rate loadings are illustrative and vary by syndicate.
Underwriting — Worked examples (group PA, sports disability)	ILLUS	Fully illustrative. Real premia depend on specific risk characteristics and market conditions.
Rates Analysis — Rate index charts, loss ratios, ROE scenarios	ILLUS	Direction and relative magnitudes consistent with market knowledge; specific percentages are illustrative.
Risk Mitigation — FCA Consumer Duty, GDPR, MLC, Equality Act	VER	Regulatory requirements verified from primary sources.
Global Programme — Territory compulsory requirements	EST	High-level country summaries consistent with market knowledge; local regulatory requirements change frequently. Always verify with local counsel.
Global Programme — Case study (~£6.2m p.a.)	ILLUS	Fully illustrative. Real multinational programme premium depends on benefit levels, local compliance costs and broker negotiation.

Identified Data Gaps GAP

GAP 1 — Lloyd's K-Series GWP by Code Lloyd's does not publicly report gross written premium broken down by individual K-series codes. Total A&H GWP is estimated from market reports and syndicate disclosures. A definitive Lloyd's-source breakdown would significantly improve accuracy of sub-class analysis.

GAP 2 — Long-COVID Disability Duration Actuarial Data At the time of writing, the CMI is still developing formal actuarial guidance on long-COVID morbidity assumptions. Industry reserving assumptions for long-COVID disability duration (particularly severe cases) vary substantially between carriers. No market-consensus figure has been published. This creates material reserve uncertainty across group income protection portfolios.

GAP 3 — Mental Health Claims Frequency Increase — Definitive Industry Figure Estimates of mental health claims frequency increase (cited as ~40% vs. pre-pandemic baseline) are derived from industry body surveys and individual insurer disclosures, not a centrally compiled market statistic. ABI and Swiss Re publish directional data but not a definitive aggregated frequency measure.

GAP 4 — Lloyd's 9/11 PA & Life Claims — Disaggregated Figure Lloyd's total 9/11 net loss was approximately $2.5–3bn across all lines. The PA and life component specifically is not separately published in publicly available Lloyd's accounts. Aviation PA and group life losses are estimated from aggregate figures.

GAP 5 — Sports Disability (KS) Market Premium Volume Lloyd's sports disability market premium is a niche, specialist class. No public market-level statistics on total KS GWP, loss ratio or combined ratio are available. Individual high-value policies (professional athletes) are placed on a confidential bilateral basis without public disclosure.

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