Mobile App Development for UK InsurTech — FCA Built In

FCA Consumer Duty in InsurTech Mobile Apps

FCA Consumer Duty (PS22/9) applies to InsurTech mobile apps — four outcome areas. Consumer Understanding: policy information must be presented clearly in the app (not buried in PDFs), renewal prices must be clearly communicated before automatic renewal, and cancellation must be as easy to find as purchase. Consumer Support: complaint pathway must be clearly accessible from the app. No dark patterns in renewal or upsell flows.

App Store Insurance Compliance

Apple App Store and Google Play have specific insurance app requirements. Apple: finance category apps handling sensitive financial transactions require additional review. FATCA/AML: apps collecting payment card data must use Apple Pay or Stripe — not custom card forms. UK FCA ICOBS 8: digital first notification of loss (FNOL) must be accessible, with confirmation of receipt to claimant.

UK GDPR App Store Privacy Labels for InsurTech

Apple Privacy Nutrition Labels and Google Play Data Safety are legally relevant for UK InsurTech. Insurance apps collect: health data (life insurance, health insurance), financial data (payment history, banking information for premium collection), location data (motor insurance telematics), and biometric data (face ID for authentication). All must be declared accurately.

Telematics Data Architecture for Motor InsurTech

Usage-based insurance (UBI/telematics) mobile apps collect driving behaviour data. UK ICO guidance: telematics data is personal data under UK GDPR. Basis: contract performance (necessary to provide the telematics insurance product). Data minimisation: collect only driving behaviour metrics needed for premium calculation (distance, time of day, speed vs limit, harsh braking) — not continuous GPS tracking unless strictly necessary.

FCA

Consumer Duty

ICOBS

UK GDPR

PECR

App Store Privacy Labels