This section of our website covers our approach to complaints about caravan insurance policies.
We set out some of the common complaints we see in relation to this type of policy – and our approach when we consider:
There are three main types of caravan – and the type of caravan often affects the type of insurance available. The three main types are:
Caravans vary enormously – but generally have common features such as living space, and amenities such as cooking and sanitary facilities.
Most caravan insurance policies are designed to cover loss or damage caused by one or more of the following events:
This list is not exhaustive. The exact terms and conditions, and the cover provided, varies between policies. Some policies include insurance for additional items such as bicycles and fridges. And some also provide benefits in other situations, for example:
Common complaints that we receive from consumers are that:
Depending on the type of complaint, we will usually look at:
If the complaint relates to a disputed claim, we will also consider the claims file (including the claim forms – and information from the claims handlers and loss adjusters, if instructed).
We sometimes see cases where the insurer disputes whether the consumer owned either the caravan or its contents. In these cases, we take into account information from the consumer – including any evidence that they may provide.
We may ask to see any of the following as evidence of ownership:
The consumer may not always have a registration document. But many do so, as motorhomes can be registered with the DVLA using the V5 registration document.
In addition, touring caravans may be part of the HPI Caravan Registration and Identification Scheme (CRiS). This is a register of caravans manufactured by members of the National Caravan Council (NCC).
Caravans manufactured since 1992 by NCC members are recorded on the CRiS database by way of a Vehicle Identification Number (VIN). The VIN and a description of the caravan are recorded on a Touring Caravan Registration Document, which is sent to the caravan’s registered owner.
Caravans manufactured prior to 1992 – or imported into the UK – can be manually registered with the CRiS by the owner.
We also see cases where the insurer disputes whether the consumer had an "insurable interest" in either the caravan or its contents. This might be the case where the consumer:
In these cases, we may ask to see evidence of the "insurable interest" (for example, a rental agreement).
We sometimes see cases where the insurer disputes whether there was any loss or damage caused to the caravan or its contents. In these cases, we may ask to see any of the following, as evidence of loss or damage:
In these cases, we take into account information from the consumer – including any evidence that they may provide.
We sometimes see cases where the insurer disputes whether the damage was caused by an insured event. In these cases, we assess who the obligation is on to prove whether there was an insured event – and whether they have satisfied that obligation.
If the consumer and the insurer produce conflicting evidence, we might undertake some limited analysis of our own. For example, If the damage is alleged to be caused by a storm, we may check the weather reports for that specific date.
Many caravan insurance policies stipulate that theft cover will not operate unless the consumer has taken various security measures. The specific measures required will vary between policies, but may include the requirement that the caravan should be:
In addition, if the caravan is of high value – usually valued in excess of £5,000 – it might be required to have additional security, such as its own security lighting.
Where a policy stipulates that a caravan – when not in use – should be kept at a storage site that meets certain requirements, what is required will vary between policies. But it may include requirements that the site should:
If the policy requires that the site is an "approved site", this will mean different things in different policies. In some cases, it will mean that the site must simply be approved by the Caravan Storage Site Owners’ Association (CaSSOA). But other policies will require the site to have a particular standard of approval from the CaSSOA – for example, for it to be gold registered.
Where the insurer has refused to pay a claim because of a term or exclusion in the policy, we will consider whether that term or exclusion was significant or unusual.
If we decide it was, we will look at how the term or exclusion was communicated to the consumer. We usually expect financial businesses to highlight significant or unusual terms or exclusions to consumers at the point of sale.
We are likely to uphold a complaint about a claim being rejected if we find that:
We are likely to be satisfied that a term or exclusion was brought to the attention of the consumer, if it was:
So if a significant or unusual term or exclusion was mentioned only in a policy document or in the renewal literature, we are unlikely to say that this was enough to bring it to the consumer’s attention.
In general, we view security requirements as significant terms – because they are not matters of obvious common sense for many consumers and they allow claims to be rejected if they are not satisfied.
Some insurers seek to rely on a question on the proposal form about security arrangements. But we will usually say that this is not enough to bring the requirements to the attention of the consumer.
Insurers sometimes include a large number of terms and exclusions which can significantly reduce the cover provided. Where we see a complaint about a claim being rejected in these circumstances, we will consider whether the limited extent of cover was adequately brought to the consumer’s attention.
We also see complaints where an insurer has sought to void the policy on the basis that the consumer provided incorrect information at the point of sale – meaning that the security requirements were never satisfied. For example, the consumer may have incorrectly told the financial business that the caravan was fitted with a certain type of lock.
We will usually expect the insurer to show that it had agreed to issue cover only on the basis that the consumer had the specific locks which they incorrectly claimed to have. In our view, protection under the policy is generally lost only if the failure to comply with the security requirements is relevant to the loss.
Once the consumer has proved that they own (or have an "insurable interest" in) the caravan or its contents – and we have assessed whether there was loss or damage caused by an insured peril – it is for the insurer (if it is refusing a claim) to show that a condition of the policy has been breached, so that it does not have to settle the claim.
Most of the cases that we see are where a consumer has failed to comply with the policy’s minimum security requirements – and so the insurer rejects the claim because of the breach of a condition of the policy.
Where disputes about breach of conditions arise, we look at:
Most caravan insurance policies are based on the principle of "indemnity". This means that, in the event of a valid claim, the insurer is obliged to put the consumer in the position that they were in prior to the loss or damage. This can be done in one of three ways:
However, there are an increasing number of "new for old" caravan insurance policies. This means that the consumer will simply get a new item for the lost or damaged one.
We often see complaints about the settlement of claims that relate to either the standard of the repairs carried out or the length of time they took. Our position is that if the insurer decides to arrange to repair the damage, it is obliged to ensure that the repairs are carried out to an adequate standard and in good time.
In these cases, we will examine photographic and expert evidence – as well as the consumer’s own statements – in deciding whether repairs are adequate.
We also see complaints where a cash settlement was offered instead of repairs – but the consumer does not think that the settlement offered is adequate. In deciding whether to uphold a complaint like this, we look at estimates for the cost of repairs provided by both sides.
If a caravan or motorhome is treated as a total loss (popularly known as a "write-off"), we will assess its market value by reference to relevant trade guides. Where this is not possible, we will look to other sources – for example, information from retailers and manufacturers, and advertised prices. We will generally treat advertised prices with caution, as they tend to include a margin for negotiation.
There is more information about our approach to this in the section of our website on motor insurance: vehicle valuation
If the consumer is due money as a result of our decision to uphold a complaint, we will usually decide that interest at the rate of 8% per annum simple (less any tax properly due) should be added – from the date of the loss or damage to the date of the settlement.
In some cases, we may also tell the business to compensate the consumer for distress and inconvenience.
If we decide that the insurer wrongly refused to consider the claim, we will usually direct it to reassess it in accordance with the policy – and with good industry practice.
If we decide that the insurer considered the consumer’s claim and wrongly refused to settle it, we will usually tell it to meet the claim – and carry out repairs, or provide a replacement, or pay the sums that are due under the policy.
If we decide that the policy was mis-sold, because the consumer was not made aware of a significant exclusion or limitation, we will usually tell the insurer to reassess the claim as if the exclusion or limitation does not apply.
If we decide that the insurer did not arrange for repairs to be carried out to an adequate standard, we will usually tell it to have the repairs improved – until they are adequate.
In some cases – usually where the repairs were inadequate on an ongoing basis – we might decide that the caravan should be written-off. There is more information about our approach to this in the section of our website on motor insurance: vehicle valuation.
If we decide that a cash settlement offered is not sufficient, we will tell the insurer to pay the appropriate amount.
The following information may also be helpful:
contact our technical advice desk on 020 7964 1400
This is part of our online technical resource which sets out our general approach to complaints about a wide range of financial products and issues. We would like your feedback on how helpful you found it. Please also use the feedback form below to tell us about anything you think we could clarify or explain better.