Price has always been powerful in insurance. What has changed is how closely regulators are now listening to the language used to describe it.
Over the past year, the Advertising Standards Authority has materially tightened its stance on pricing claims. Recent rulings make it clear that how firms talk about price is no longer a marketing detail. It is a governance issue.
This matters for insurers because price does not live in isolation. It is shaped by assumptions, conditions and trade-offs that are rarely visible when a single number is put front and centre.
Across the market, consumers are routinely told that they can lower premiums by adjusting inputs such as voluntary excess. That messaging appears consistently across the major price comparison websites, including Confused.com, Compare the Market, GoCompare and MoneySuperMarket.
In isolation, these statements are often factually correct. Increasing excess can reduce premium. The regulatory issue is not whether the statement is true. It is whether the statement is complete.
Recent ASA rulings show a clear direction of travel. Claims that imply guaranteed savings, best prices, or optimal outcomes are being treated as objective claims. Where firms cannot demonstrate that those outcomes apply broadly and consistently, the ASA has been willing to intervene.
The December 2025 ruling against UK rail operators is instructive. Language suggesting consumers would find the “best” or “cheapest” price by booking direct was ruled misleading because it implied a guarantee that could not be substantiated. The absence of malicious intent was irrelevant. What mattered was how the claim would reasonably be understood by the consumer.
Similarly, rulings on promotional pricing and reference prices have reinforced that savings must be real, representative and evidenced. Where discounts are based on prices that were rarely charged, or where only a small proportion of consumers could achieve the headline outcome, the ASA has concluded that the overall impression was misleading.
These rulings sit alongside long-standing CAP Code principles. Price claims must be clear, must not omit material information, and must not exaggerate the benefit likely to be achieved by the typical consumer. What has changed is the intensity of enforcement and the regulator’s willingness to challenge implied meanings, not just explicit wording.
For insurance, the implications are significant.
Price is rarely a fixed attribute. It is the result of configuration choices. Excess, cover limits, endorsements, underwriting assumptions and consumer behaviour all interact to produce the final premium. When communications focus on the premium alone, without anchoring that price in the context of affordability and usability, they risk creating a distorted impression of value.
This is particularly relevant when high excess strategies are used to achieve competitive price positioning. At a certain point, the product being offered is no longer meaningfully comparable to standard protection. The consumer may technically be insured, but practically exposed. If communications celebrate the price outcome without explaining that trade-off, the risk is not just consumer misunderstanding. It is regulatory challenge.
Language also travels. Phrases that originate in consumer guides often reappear in broker packs, trading updates, press commentary and internal performance narratives. When firms talk about “winning on price” or “driving price down” without framing what has changed underneath, they create statements that are fragile under scrutiny.
The strongest firms are responding by changing how they talk about price, not by abandoning competitiveness. They are moving away from absolutes and towards conditions. They explain that price reductions are possible within boundaries. They are explicit that lower premiums can come with higher retained risk, and that value is defined by outcomes, not just entry price.
This approach aligns far more closely with both Consumer Duty and ASA expectations. It recognises that factual accuracy is necessary but no longer sufficient. What matters is the overall impression created.
At Consumer Intelligence, our evidence consistently shows that price signals without context are unstable. They move quickly and can lead decision-makers to false confidence. Contextualised pricing, by contrast, supports better commercial decisions and more defensible external narratives.
The regulatory direction is clear. Price claims are being assessed not just on what they say, but on what they imply. Firms that continue to treat price as a standalone headline are taking on unnecessary risk.
Price remains powerful. The firms that will succeed are those that use it precisely, explain it honestly, and anchor it firmly in the reality of consumer outcomes.