I got this reply from the Central Bank
The General Principles of the Consumer Protection Code 2012 provide that a regulated entity must ensure that in all its dealings with customers and within the context of its authorisation it “makes full disclosure of all relevant material information…in a way that seeks to inform the customer”. Provision 4.1 of the Code provides that “key information must be brought to the attention of the consumer” and that “the method of presentation must not disguise, diminish or obscure important information”. ‘Key information’ is defined in the Code as “any information which is likely to influence a consumer’s actions with regard to a product or service”.
The issue has been passed to our Insurance Supervision teamin the Consumer Protection Directorate for consideration.
It is worth noting that in 2016, the Central Bank undertook a themed inspection of the renewal of health insurance plans. The themed inspection found that annual renewal notices do not provide sufficient information to consumers to make informed decisions about their health insurance. As a result of the inspection, the Central Bank introduced a number of additional protections for consumers when renewing their health insurance policies. Health insurance providers are now required to:
· Encourage consumers to make contact with the provider to ensure the provider assesses if there are more suitable policies available, and
· Clearly explain to consumers that their policy will auto-renew if they do not contact their insurer prior to their renewal date.
Health insurance providers must now include an information box in their renewal notification letter to encourage customers to contact their health insurer and discuss their health insurance needs each year rather than let their policy auto-renew.