Written by · Reviewed by Smiths Insurance & KiwiSaver — licensed Financial Advice Provider (FSP712931) · Last updated 2026-10-20

The Fair Insurance Code in NZ: who it covers and how to complain

The Fair Insurance Code is a conduct code written by the Insurance Council of New Zealand (ICNZ). It applies to ICNZ's member companies and covers general insurance only: it does not cover health or life insurance. It sets service standards from first contact through claims and complaints, including acknowledging a complaint within 5 business days and responding within 10 business days. Life and funeral insurance products are outside this code.

In short

What the Fair Insurance Code is

The Fair Insurance Code is a code of conduct from ICNZ that sets the level of service its members must provide. ICNZ says it "applies to all ICNZ members companies" and describes what service you can expect from your first contact with your insurer. Its obligations are in addition to those imposed by law. The most recent version took effect on 1 April 2020 (ICNZ: About the Code).

ICNZ's page makes three points that matter for scope:

We have not listed which insurers are members; ICNZ keeps that list, so check there.

What it promises on complaints

ICNZ's complaint guide sets out these steps (ICNZ: Making a complaint):

  1. Complain to your insurer first.
  2. The insurer must acknowledge receipt within five business days.
  3. It must respond within 10 business days.
  4. If it is not resolved within two months, the insurer must tell you about its external dispute resolution scheme. You can go to the scheme after two months, or sooner if you receive a deadlock letter.

ICNZ lists the two schemes its members belong to: Financial Services Complaints Limited and IFSO. Both are free for customers. They cannot review commercial decisions such as premiums or policy terms, and disputes over $500,000 (plus GST if applicable) go to a court. ICNZ's page states timeframes for insurers but no deadline for you to complain.

For significant, unresolved breaches, ICNZ's Code Compliance Committee can investigate. The ICNZ Board can reprimand a member, end its membership or impose a fine of up to $100,000.

Where life and funeral policyholders complain

The Code does not apply to a Momentum Life policy, so use the insurer's own process. The Financial Markets Authority says to "make a complaint directly to your insurance company, or their dispute resolution scheme" (FMA: Insurance). The FMA also says it "can't obtain remedies for individuals" (FMA: Disputes and consumer protection).

Momentum Life's published process, from its Quick Life wording and complaints page, runs like this (Momentum Life: Complaints):

  1. Contact Momentum on 0800 108 108 or [email protected]. It says it will acknowledge a complaint within 2 business days.
  2. If customer care cannot resolve it, the complaints manager aims to reply within 10 business days.
  3. Next, the internal dispute resolution team aims to give a formal response, usually in writing, within 2 months.
  4. If there is still no resolution, a letter of deadlock is issued and you have up to 3 months to take the complaint to IFSO.
  5. IFSO is free and independent. Momentum's Funeral Insurance wording says an IFSO assessment is binding on Momentum Life.

See our guides to Momentum Life complaints, funeral insurance disputes and insurance complaints.

Fair Insurance Code or FSC Code of Conduct?

Fair Insurance Code FSC Code of Conduct
Written by Insurance Council of New Zealand Financial Services Council
Applies to ICNZ member companies "All FSC members"
Type of insurance General insurance only Not limited on the FSC page we read
In force Latest version 1 April 2020 "Came into effect on 1 January 2019"
Enforcement Schemes apply it; ICNZ committee for significant breaches; fines up to $100,000 Independent disciplinary committee; fines up to $100,000; expulsion
Complaint timeframes 5 business days to acknowledge; 10 business days to respond Complain to the provider first; its process then applies

Sources: ICNZ and FSC: Code of Conduct. The FSC code has nine standards in three groups: a principal ethical standard, customer communication, and good customer outcomes. Whether a particular life insurer is an FSC member is something to ask the insurer or check on the FSC site; we have not verified any insurer's membership.

The law sits underneath

Codes add to the law, they do not replace it. Every business offering retail financial services must belong to an approved dispute resolution scheme; four exist: the Banking Ombudsman Scheme, IFSO, Financial Services Complaints and the Financial Dispute Resolution Service (FMA: disputes and consumer protection). Under the Conduct of Financial Institutions regime, licensed insurers also need a financial institution licence and a written fair conduct programme that meets the minimum requirements in the Act (FMA: Financial institutions). We did not confirm what that programme must say about claims, so read an insurer's published summary for its own commitments.

A separate point: from 15 November 2027 (not yet in force), the Contracts of Insurance Act 2024 will change the rules on disclosure and remedies. It is not a complaint code.

If a claim has been declined

Start with the insurer's complaint process and keep a record of dates. For a declined life claim, see how to claim life insurance and what to do if an insurance claim is declined. IFSO's limits for disputes referred after a deadlock on or after 18 July 2024 are $500,000 plus GST, or $2,798 plus GST a week for regular payments (IFSO FAQs); recheck these on IFSO's site before relying on them.

If you are looking at Momentum's guaranteed acceptance plans, note that Momentum Life Limited has an A.M. Best financial strength rating of B (Fair), a range Momentum's own table calls "Vulnerable"; see its financial strength page. The buttons on this page open Momentum's online application. Funeral Insurance pays only for accidental death in its first 24 months, and Quick Life excludes pre-existing conditions and suicide for the first 2 years. See guaranteed acceptance and the funeral insurance hub.

General information, not advice. Advice is provided by Craig Smith Business Services Limited, trading as Smiths Insurance & KiwiSaver, a licensed Financial Advice Provider (FSP712931). QuoteHub is a Momentum Life partner, and Smiths Insurance & KiwiSaver may receive a commission if you buy through our link; see how we are paid. For a complaint about QuoteHub's own service, see the dispute scheme named on our disclosure page. Last reviewed 20 October 2026.

Frequently asked questions

Does the Fair Insurance Code apply to life insurance?

No. ICNZ's page says the Code does not cover health or life insurance.

Who do I complain to about a life insurer?

The insurer first, then the dispute scheme it belongs to. Momentum Life's scheme is IFSO.

Is there a deadline to complain?

ICNZ's page sets timeframes for insurers, not a deadline for you. Under Momentum's process you have up to 3 months after a deadlock letter to go to IFSO; check the scheme's current rules.

References

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