AA Underwriting Insurance Company Limited · DRN-6048656

The complaint Mr D complains that AA Underwriting Insurance Company Limited (“AA”) responded unfairly to his notification of an incident in connection with his motor insurance policy. What happened The subject matter of the insurance, the incident and the complaint is a car, first registered in 2017. Mr D acquired the car in 2019. For the year from July 2024, Mr D had the car insured on a policy with AA. He had a no- claims bonus (“NCB”) that was “protected”. In late September 2024, Mr D notified AA that the car had been involved in a minor and low- speed contact with a third party’s vehicle. Mr D reported that there had been no damage to his car or the other vehicle. During the call, AA asked Mr D about convictions. Mr D mentioned a convection “many years ago”. AA involved its policy validation team. Mr D complained to AA including that it had threatened to void his policy. By a final response dated 14 November 2024, AA turned down that complaint. The final response included the following: “…your original intention was to log this as an information-only report. I can see that during your FNOL call, the agent advised that they would fulfil this request, and I can confirm that the claim was closed as information only on [broker’s] system. However, as the circumstances of your incident are that of a fault claim, the report was also passed to AAUICL’s system. Your underwriter has jurisdiction to manage these claim types, and the claim is unable to close as information-only on their system until it has remained open for 90 days. This time frame allows for any third-party claim to be received. After this period, if no third-party claim is filed, we can honour your intention for the report to be treated as information only. It is important to note that, even if the report is closed as information-only, if any third-party claim arises within six years, we will reopen the case for further review. These policy validation checks are standalone checks and are not indicative of a claim.” I’ve added the underlining and I will come back to that. After the final response dated 14 November 2024, Mr D didn’t bring his complaint to us within six months. In late June 2025, AA sent Mr D documents for a renewal for the year from July 2025. Under the section on “Accidents, Claims or Losses” the incident in September 2024 was noted as follows:

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“Incident description At fault? Third Party Hit Driver in Rear No” Mr D and AA renewed the policy. The incident appeared in the same way in the policy documents. Mr D complained to AA that it had mis-recorded the incident. He also complained to AA again about the validation process. By a final response dated 23 September 2025, AA accepted that its validation process had been unnecessary. AA said it was sending Mr D a cheque as compensation for the upset it had caused. Mr D brought his complaint to us on 24 September 2025. Our investigator said that he didn’t have jurisdiction over the previous complaint in 2024. That was because Mr D hadn’t brought it to us in time. Our investigator also said that he couldn’t investigate Mr D’s complaint that AA had forgotten his complaint and wasted his time on the phone. That was because Mr D hadn’t made that complaint to AA. Our investigator didn’t recommend that the complaint about mis-recording should be upheld. He didn’t think that AA acted unreasonably with how it recorded the road incident or with how the incident appeared in Mr D’s policy documents. Mr D disagreed with the investigator’s opinion. He asked for an ombudsman to review the complaint. He says, in summary, that: • Insurance companies collect data by recording incidents where no claims are made or allowed under the terms of the policy. There is an on cost to the public. • AA in reaching their outcome considered the complaint as a whole and not partitioned. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Scope of this decision The Financial Conduct Authority’s dispute resolution rules bind the Financial Ombudsman Service. One such rule is that if a consumer makes a complaint to a regulated firm and receives a final response but doesn’t bring the complaint to us within six months, then we can’t investigate it. That is unless the firm consents or exceptional circumstances have prevented the consumer from complying with the time limit. It sometimes happens that a firm sends an earlier final response and a later final response which each relate (at least in part) to an earlier complaint. If that happens, then we look to see whether the later final response is (at least in part) a re-opening and review of the earlier final response. To the extent that it is, we consider that the six-month time limit runs from the later final response.

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In Mr D’s case, the later final response dated 23 September 2025 started as follows: “Thanks for speaking to us about the service received on your complaint, I have completed my review of the outcome we provided dated November 2024.” So I consider that it was a re-opening and review of the earlier final response. I will treat Mr D’s complaint about the validation process as having been brought to us in time. The final response dated 23 September 2025 also included the following: “I can appreciate also your frustration at the coming together of a TP as you described to me, that has not as yet resulted in any Claim cost, please be advised I have not reviewed this aspect of your complaint as the outcome remains unchanged.” From what Mr D and AA have each said, I’m satisfied that Mr D had, from about late June 2025, complained to AA that it had mis-recorded the 2024 incident. AA didn’t provide a final response to that complaint. I consider that our investigator was right to investigate that complaint and I will include it in the scope of this decision. Unfortunately, the handling of complaints is not itself a regulated activity, so we don’t have jurisdiction to investigate complaints about it. Our investigator didn’t investigate Mr D’s complaint that AA had forgotten his complaint and wasted his time on the phone. I don’t include that in the scope of this decision. This decision Different insurers assess risk and set premiums in different ways at different times. That said, insurers will often assess risk and premiums at a higher level for a driver who has been involved in an incident or accident (and more so if it results in a claim). The later final response dated 23 September 2025 included the following: “The Validation process was invoked by AA, whilst we were clear this can be performed at any time during the policy year, after consulting with our Validations team, I am of the opinion this was not necessary in a Claims process and would agree we could of made the actions taking place at the time easier to understand” From that, and from my review of the file, I find that AA unnecessarily put Mr D to the trouble of documenting an offence that was over twenty years old. I accept that AA made Mr D feel he was being investigated for deliberate misrepresentation and that he was in jeopardy of having the policy voided. I find it likely that the impact on Mr D included inconvenience, indignation, irritation and concern about future insurance. Mr D has been at pains to say that he never asked for compensation. AA acknowledged that in the final response dated September 2025. Nevertheless, AA has more recently sent Mr D a cheque for £150.00. I’m satisfied that this amount is fair and reasonable and in line with our published guidelines for compensation for distress and inconvenience. Mr D didn’t make a claim and AA hasn’t said that the third party made a claim. So it wouldn’t be correct that Mr D had been involved in a claim or a loss.

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Notwithstanding the underlined words “the circumstances of your incident are that of a fault claim”, I’m satisfied that AA correctly recorded the incident on the Claims and Underwriting Exchange database (“CUE”) as “notification only” with no outlay (so not a claim) and allowed for NCB (so not a fault claim). However, I find it fair to say that Mr D had been involved in an accident, albeit one of the most minor sort. So I don’t find that AA treated Mr D unfairly by including the September 2024 incident on the renewal quote and renewed policy documents under the heading of “Accidents, Claims or Losses”. Also I’ve noted that compared to 2024, the 2025 quote was not unfavourable to Mr D. Overall I don’t find it fair and reasonable to direct AA to do any more in response to this complaint. My final decision For the reasons I’ve explained, my final decision is that I don’t uphold this complaint. I don’t direct AA Underwriting Insurance Company Limited to do any more in response to this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr D to accept or reject my decision before 24 April 2026. Christopher Gilbert Ombudsman

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