Chapter 3 - Issues with the operation of the pool

Chapter 3Issues with the operation of the pool

3.1As outlined in Chapter 2, the Cyclone Reinsurance Pool is clearly having a positive impact, even if it is not as much as expected. However, under-insurance and non-insurance remain problematic in some areas, and the high inflation of insurance around Australia is impacting premium pricing.

3.2Witnesses at the committee’s public hearings were largely in agreement that further changes could improve the operation of the pool. For example, the Royal Automobile Club of Queensland (RACQ) told the committee that ‘the pool could have been a lot better than was ultimately legislated’.[1]

3.3The Australian Consumers Insurance Lobby acknowledged in February 2025 that it was somewhat more optimistic about the benefits of the pool than it was when it gave evidence at the April 2024 public hearing. However:

… the promises were that savings would be significantly more than what they are. They’re not. The reason for optimism is that we are here today to outline changes that are needed to get to that level of saving … Consumers are not seeing the savings that they need or expect, but we do believe that, with the right changes, you can get there.[2]

3.4The key questions the committee considered during this inquiry included the following:

Whether certain aspects of the pool should be amended to improve its policy objective of ‘improving insurance access and affordability for households and small businesses in cyclone-prone areas of Australia’.[3]

Whether the pool should be expanded in terms of the types of risks it covers – in particular, floods unrelated to a cyclone event.

What other measures are or should be in place to improve insurance availability and affordability.

3.5Accordingly, this chapter considers the key reasons for the increased cost of insurance across Australia, which has reduced the anticipated benefits from the establishment of the pool. The chapter then outlines proposals in evidence about possible changes to the pool to improve outcomes for consumers in Northern Australia. These include:

whether marine insurance should be covered by the pool;

the expansion of business insurance above the current threshold of $5 million total sum insured;

ongoing issues with strata insurance coverage and cost in Northern Australia; and

whether the pool should continue to provide cover for 48 hours after the end of a cyclone, or for a longer period.

3.6Chapter 4 examines other measures to address insurance availability and affordability, including whether the pool should be expanded to cover flood risk. The committee’s view on the matters and recommendations discussed in both chapters are set out in Chapter 5.

3.7The committee also received a small amount of evidence calling for changes to other areas related to the pool’s scope, including:

farm insurance;[4]

motor insurance;[5]

changes to how aged and disability settings are recognised;[6]

subsidisation ‘from some of the lower risk consumers to high-risk consumers’ to bring down premium prices;[7] and

barriers to entry for new insurers to the market, including mutuals.[8]

3.8Given the limited amount of evidence received on these matters, the committee does not discuss these issues further in this report.

Increased cost of insurance

3.9In its September 2024 monitoring report into the implementation and impact of the pool, the ACCC noted the pool ‘is beginning to deliver premium relief for some consumers in some regions facing higher risk of cyclones’ but that these ‘cost savings generated by the pool have been offset to varying extents by other cost increases’.[9]

3.10RACQ noted that it had seen increases in the amount of excess that policy holders are opting for in their policies, indicating potential issues with premium affordability. In addition, RACQ had ‘seen coverage on contents often being reduced or dropped altogether and we have seen some people reduce their sum insured, which we take to be an affordability issue’.[10]

3.11In April 2024, the ARPC acknowledged that communities in Northern Australia ‘would like to see larger savings’ but also noted that Northern Australia is likely ‘the only part of Australia that’s getting price reductions at the moment in the insurance sector’ because of ‘significant price increases’ in the cost of insurance.[11]

3.12The committee received evidence outlining three key reasons for increases in the cost of insurance premiums in Northern Australia, namely:

1)increased building costs, in the face of a national housing crisis;

2)an increase in extreme weather events, causing broader increases in the price of insurance around the world; and

3)whether insurance companies were posting record profits because of the premiums they are charging policy holders.

Increased building costs

3.13According to the Insurance Council of Australia (Insurance Council), the benefits of the pool on premium costs ‘are being eroded because of inflation and other price pressures’, such as a ’40 per cent increase in the cost of rebuilding in three years’ and a national housing crisis to accommodate builders and tradespeople.[12] In particular, the Insurance Council pointed to inflationary pressures in construction, noting that the ‘cost of repairing or rebuilding a home is now 27 per cent higher than it was at the start of the COVID-19 pandemic’, with Queensland experiencing the highest growth rate.[13]

3.14The committee examined the issue of housing affordability and availability in Northern Australia at length in the Workforce Development inquiry, in acknowledgement of housing being one of the key issues for workforce development in the region. The First Report for that inquiry, tabled in November 2023, made four recommendations intended to improve housing supply and the cost of housing.[14] The Australian Government is yet to respond to those recommendations, or a further recommendation the committee made on housing in the Final Report for that inquiry, tabled in November 2024.[15]

Impact of natural disasters on the cost of insurance

3.15The Insurance Council also highlighted the ’increasing frequency and severity of natural disasters’ and referenced 2022 research projecting that the cost of extreme weather events is anticipated to grow by five per cent each year. They reported that reinsurance premiums have increased by up to 30 per cent because of the risk posed by Australia’s worsening weather, and the recent wildfires in Los Angeles may lead to increasing pressure on reinsurance premiums globally.[16]

3.16At the April 2024 hearing, Suncorp similarly informed the committee that the reinsurance market is currently ‘what’s called a “hard market”. Global premiums for reinsurance are actually higher’.[17]

Insurer profits

3.17In response to questions about recent, significant year-on-year increases to insurer profits,[18] the Insurance Council argued that these reflected a recent recovery from relatively low levels and informed the committee that, between 2020 and 2023, insurers made, on average, $1.50 for every $100 of premium collected. This compared to $5 for every $100 of premium collected from 2012 to 2020. In addition, the Insurance Council suggested that this ‘recovery’ in recent years was not necessarily a reflection of more income generated from premiums but, rather, from ‘investment returns. In other words, the higher interest rates that the country has been enduring actually return more money to insurers’, with business insurance cross-subsidising home and contents insurance ‘for a number of years’.[19]

3.18On being asked what levers are being used so insurers are actually passing on savings generated from the pool to consumers, the Insurance Council responded:

The ACCC’s most recent insurance monitoring report demonstrates that all insurers in the Pool intend to pass through any savings achieved by the Pool to consumers. There are varied approaches in how insurers are passing on the ARPC reinsurance premiums to consumers, and this is due to different systems and existing (pre-Pool) pricing approaches.

The Insurance Council does not collect data on profitability in particular areas ….[20]

Proposed changes to the pool

3.19The committee heard that, as currently structured, the pool is not providing sufficient coverage in several key areas:

marine insurance;

insurance for businesses;

strata insurance; and

damage caused beyond the 48 hours after a cyclone is downgraded, despite this damage in some instances being more significant than the damage caused during the cyclone itself.

Marine insurance

3.20In the First Report for this inquiry, tabled in March 2023, the committee recommended that the Australian Government announce a position on the inclusion of marine insurance in the pool.[21] Following the tabling of the First Report, the committee received subsequent evidence calling for the inclusion of marine insurance in the pool’s coverage.[22]

3.21The Australian Consumers Insurance Lobby critiqued what it argued are ‘misleading claims’ from the insurance industry ‘that marina insurance in the pool would have only a five per cent impact on consumers’.[23]

3.22Insurance Australia Group considered that including marine-related infrastructure in the pool’s coverage ‘would likely involve additional cost to the ARPC and a higher premium charge by the cyclone reinsurance pool to insurers’. It expressed its commitment to working ‘constructively with the government on solutions to improve the affordability of marine insurance in Northern Australia’.[24]

3.23Conversely, Suncorp, while acknowledging that it had only a ‘small book of marine insurance’, suggested that expanding the pool to cover marine insurance would ‘probably not’ be ‘a significant cost to the pool’ because marine insurance claims for losses from cyclones tend to be ‘fairly small’ relative to large property losses.[25]

3.24The Australian Consumers Insurance Lobby also questioned whether the inclusion of marine insurance would ‘blow the cost of [reinsurance] out’. Mr Tyrone Shandiman argued:

The first thing is that you've got two types of marine insurance. You've got fixed infrastructure and then you've got boats, which are not fixed. I think, at the very least, just focus on fixed infrastructure like marinas, jetties and pontoons. To suggest that that's going to blow the cost of insurance out—I would completely disagree with that, because if you look at things like the Airlie Beach marinas in your area, they're $20 million to rebuild. The pool collects $1 billion a year. How is that going to blow costs out significantly for consumers? So I don't agree with the assertion that this is going to significantly increase the cost of insurance because I don't believe there is enough property there to have such a significant impact on the pool. We would at least advocate, at the very minimum, looking at fixed marine infrastructure and including that in the pool.[26]

3.25At the April 2024 hearing, QBE proposed further modelling be undertaken ‘to understand whether, in fact, there is much relief that the pool could provide to marine before we seek to include marine policies into the pool’.[27]

3.26The committee has not yet received a response from the Australian Government to its previous recommendation. In response to a question about this matter at the public hearing on 7 February 2025, Treasury informed the committee that it had conducted modelling on the impact of the inclusion of marine insurance in the pool in 2022, and:

… we are aware of that recommendation. Treasury has provided advice to government on that matter. The timing and release of any government position on marine insurance, or, for that matter, the recommendations of the report, is a matter for government.[28]

Business insurance

3.27The pool currently covers commercial property policies with less than $5 million total sum insured across risks covered by the pool and Small Medium Enterprises (SMEs) up to a maximum of $5 million sum insured.[29]

3.28However, the Townsville Chamber of Commerce (the Chamber) informed the committee that insurance was unavailable for some businesses, ’including and above $5 million … because of the lack of competition in the marketplace’.[30]

3.29The Chamber acknowledged that in previous submissions, it had ‘highlighted the issue of defining a business size by sum insured’. However, it suggested that businesses are now unable to access attainable and affordable insurance. The Chamber argued that ‘businesses need affordable and attainable insurance to operate freely, borrow money, employ staff and comply with their statutory obligations’. They called for the cap to be removed to assist businesses, arguing that removing the cap would help the pool to achieve its objectives, and increase the premiums the pool collects, thereby ‘ensuring the pool is cost neutral to the federal government’.[31]

3.30The Australian Consumers Insurance Lobby also called for the commercial limit for buildings to be increased to $20 million.[32]

3.31In the First Report, tabled in March 2023, the committee recommended that ‘future reviews of the Cyclone Reinsurance Pool consider the sum insured limit’ for businesses.[33] The Australian Government is yet to respond to this recommendation.

Strata insurance

3.32It is a mandatory, legislative requirement across all jurisdictions to purchase strata insurance at full replacement value. According to the Insurance Council, this requirement is in place ‘to ensure consumers are protected from economic losses arising from damages and to minimise the risk of underinsurance’.[34]

3.33According to the ACCC, median strata prices for insurance premiums have fallen in some high-risk cyclone areas.[35]

3.34Insurance Australia Group stated at the April 2024 hearing that ‘for strata properties that have good building quality and are covered by the pool, there will definitely be savings passed through’.[36]

3.35At the April 2024 hearing, Allianz informed the committee that some of its policy-holders had seen savings of up to 40 or 50 per cent for strata insurance because of the pool, although average savings were far less than that amount.[37]

3.36At the April 2024 hearing, the Chairperson of the Australian Consumers Insurance Lobby (ACIL) acknowledged ‘promising developments … for large strata properties in Northern Australia’ which historically have had high insurance premiums. In particular, the ACIL reported that some larger strata buildings, whose insurance premiums were 10 to 20 times the cost of insurance premiums in other parts of Australia, had seen strata premium rates reduce to about three to four times the cost of insurance premiums in the rest of Australia. Even so, the ACIL pointed to ‘real problems in the strata space’ because of the limited number of insurers in the pool offering strata insurance for buildings with a sum insured of over $20 million.[38]

3.37The ACIL suggested that some insurers are not writing new businesses in strata, telling the committee that Allianz and Chubb ‘still refuse to underwrite new business in strata’. ACIL claimed that the ‘industry justifies this by essentially saying they might have to pay a claim, which of course is the entire purpose of why they’re in business’.[39]

3.38Where a body corporate in Queensland is unable to insure particular buildings for full replacement value, the body corporate is able to make an adjudication application for an alternative order.[40]

3.39While not directly raised in evidence to this inquiry, the committee is aware that in some instances, major strata properties valued at $15 million or more are not covered by the pool because they are unable to obtain standard insurance. Some of these properties may be underwritten by international underwriters who are not members of the pool.

3.40The Insurance Council informed the committee that from the perspective of the insurance industry, strata ‘insurance priced at full replacement value helps owners corporations afford the rebuild cost of their strata complex following an insured event and reduces the risk of underinsurance’. They further argued:

Apartment owners have the benefit of sharing the cost of insurance between multiple lots of a strata complex, which helps to improve the affordability of strata insurance compared to other home buildings insurance. An insurance premium for a single lot of a strata complex is, on average, 32–26 per cent lower than that of a detached home building.[41]

3.41The Insurance Council noted ‘bigger challenges … in some of the southern states around strata insurance, and it’s largely due to building quality and waterproofing’. Further, insurers ‘are seeing costs blow out enormously in strata claims, largely driven by water damage, and that is not just cyclone related. That’s across the country’. The Insurance Council pointed to recent work in New South Wales on building standards for strata, arguing that ‘other states need to start following suit to just bring about a level of confidence for underwriters that these apartment blocks … are going to be durable for the conditions that they’re being built for’. [42]

3.42In a similar vein, Suncorp also noted that ‘it’s fairly well known that there are some challenges in the whole strata insurance space which are outside cyclone pool-type issues’.[43]

3.43The ARPC will provide insurers with premium discounts for mitigation in strata buildings from April 2025.[44]

The 48-hour rule

3.44As it currently stands, the pool covers the full duration of a cyclone as declared by the Bureau of Meteorology, regardless of how long a cyclone lasts, plus an additional 48 hours of cover after the cyclone is downgraded. The 48-hour stipulation is set out in delegated legislation.[45]

3.45The current industry standard allows insurers to recover the cost of event claims from private reinsurers up to a maximum of 168 hours, or seven days, from a point that an insurer chooses as the start of the event. Some insurers may purchase reinsurance contracts for more than 168 hours, depending on their commercial negotiations for how they place their risk internationally.[46]

3.46According to the Australian Government Actuary, the Australian Government initially decided on the 48-hour period because:

insurers wanted a clear start and end date to the period of coverage;

insurers wanted the statement on the end of a cyclone to be impartial and a scientific decision; hence, the decision that the Bureau of Meteorology would declare the beginning and the end of a cyclone event for the purposes of the pool; and

the available data and analysis suggested that the longer the period of time, the higher the likelihood that the resources of the pool would be drawn on for a broader geographic area, with the benefits of the pool spread across more policy holders paying lower premiums, who were not necessarily the reason why the pool was established.[47]

3.47At the April 2024 hearing, the ARPC informed the committee that ‘roughly 55 per cent of flood exposure in Northern Australia is modelled as being included in the pool. The balance—the 45 per cent—is the part that needs to be reinsured by insurers into the global market’.[48]

3.48The Insurance Council did not have a view at the February 2025 hearing on whether to extend to seven days, suggesting only that such a change would increase the premiums the ARPC charges insurance companies.[49] Previously, however, at the public hearing in April 2024, the Insurance Council suggested that, given the loss rate the insurance industry experiences in Northern Australia and the fact that the Government is not subsidising the pool, ‘it’s hard to see how any changes to the 48-hour rule would really, in effect, provide any relief from a premium perspective. But it’s something that could be modelled…’.[50]

3.49On the other hand, some insurers were strongly in favour of extending the period. For example, RACQ argued this would ‘align’ the pool with global reinsurance terms.[51]

3.50Similarly, Sure Insurance, which is not a member of the Insurance Council, called for the current 48-hour window of cover to be extended to 168 hours, suggesting that this would lead to further premium savings for customers. Sure Insurance pointed to its recent experience with cyclones to support this proposal:

[There is a] need to ensure that there are no gaps between the cyclone pool coverage and what traditional reinsurance cover provides—essentially to ensure that customers are not paying twice. Unfortunately, our previous concerns have been highlighted in the Tropical Cyclone Jasper scenario.

Sure holds the second-largest market share, we believe, in the Cairns home insurance market, and Sure Insurance losses from Jasper were over $94 million. However, under the current 48-hour cover definition, only 22.8 per cent of that loss will be recovered from the pool. In comparison, had the 168-hour coverage period been in place, we estimate 99.3 per cent of the losses would have been recoverable from the pool ... The question is: how has this scenario impacted the cost of insurance for Sure customers? Unfortunately, the answer is in direct conflict with the government's current cost-of-living relief efforts, with premium increases of 20 plus per cent plus being immediately requested by Sure's capacity providers when it was apparent that the majority of the loss would not be covered by the insurance pool.[52]

3.51RACQ informed the committee that 68 per cent of the claims made to it that were associated with the cyclone were not covered by the pool. RACQ noted that its earlier submissions had argued that one in two cyclones would not be ‘substantially covered’ by the pool as designed, and pointed to the pool only covering one of the two most recent cyclones at the time of giving evidence (Tropical Cyclone Jasper versus Tropical Cyclone Kirrily).[53]

3.52At the April 2024 hearing, RACQ stated that it was ‘sensing … that the reinsurance markets are observing that the pool did not cover much of [Tropical Cyclone Jasper], so they now need to think about the residual risk. The residual risk we see in cyclone events is post the cyclone being a cyclone’.[54]

3.53Sure Insurance acknowledged that coverage of the pool depends on the event, noting that costs arising from Tropical Cyclone Kirrily were ‘100 per cent covered’. However, Sure informed the committee that the recent view of reinsurers from an overseas market was ‘they can’t give the discount that they would be able to give if it were the full 168 hours. They have to assume the worst-case scenario’. As such, if ‘certainty were created for reinsurers [around the pool covering a longer window of time], it’s quite clear from them that the price would be reduced’.[55]

3.54Sure Insurance argued that given the pool’s current surplus, ‘the annual average cost of adding the 168-hour provision can clearly be accommodated’. They informed the committee that under current reinsurance arrangements, customers will be subject to, on average, a $500-plus increase per policy, as compared with a $5 increase, on average, per policy, if the period of reinsurance the pool covers was extended to seven days after a cyclone is downgraded. In particular, ‘we can undertake that a five per cent increase in pool costs by extending the time coverage will result in a net premium benefit for Sure customers by avoiding some of the duplicated reinsurance costs our customers currently incur’.[56]

3.55Other insurers, such as Insurance Australia Group, also had most of their claims for Tropical Cyclone Jasper fall outside of the 48-hour period. However, on the matter of extending the 48-hour rule, Insurance Australia Group suggested that extending the rule would mean ‘a lot more flood damage. That would mean a lot more losses for us and in the flow on to the ARPC, which would mean, in consequence, higher insurance premiums from the ARPC back to us’. Insurance Australia Group argued that extending the 48 hours would ‘effectively’ mean that the Cyclone Reinsurance Pool would become ‘a flood pool … [W]e need to look at [flood affordability] holistically rather than simply extending the 48-hour limit’.[57]

3.56The broader question about whether the pool should be expanded to include flood is considered in Chapter 4.

3.57At the April 2024 hearing, Suncorp was of the view that ‘it would make sense’ to expand coverage to accord roughly with reinsurance coverage, although ‘it’s probably not going to make a huge difference in cost to … the government or … to customers in terms of savings in premium. Cyclone Jasper was unusual … Most cyclones do downgrade very quickly and, in terms of material insurance losses, dissipate very quickly’.[58]

3.58QBE at the same hearing also reiterated its support for ‘further analysis and consideration by government to consider the 48 hours and whether that should be closer aligned to the seven days or similar effect that we see in commercial reinsurance markets’.[59]

3.59The committee in its First Report considered concerns from Allianz that extending the 48-hour period would mean ‘a dilution’ of the savings generated through the pool for people in Northern Australia, given the geographical scope of the pool could be expanded with cyclones tracking to the south over the extended period of time.[60] At the hearing in April 2024, Allianz reiterated their view that extending the 48-hour period ‘will not deliver savings to high-cyclone-risk customers and is counter to the policy intent of improving affordability in these areas’. Allianz gave the following reasons for their position:

Extending the timeframe would effectively move claims further from cyclone affected areas, potentially as far south as Melbourne, thereby diluting savings.

Insurers are able to handle additional post-48-hour flood claims through their own funds and the private reinsurance market.

An extension of the 48-hour period would primarily be a flood pooling arrangement, but the pool’s design would not be effective for high-risk flood customers, and no public modelling demonstrates that such an expansion would see premium savings for high cyclone risk.[61]

3.60Allianz also argued that the extension from 48 hours to seven days was more likely to lead to an increase in premium costs, rather than a decrease.[62]

3.61In response to this evidence, Sure Insurance’s Managing Director informed the committee that they had consulted with two senior global reinsurers who ‘would have a contrary view to that … [W]e believe the change to 168 hours, certainly in our case, would have a direct and immediate effect on being able to reduce premiums. I can’t talk for Allianz’s business model; I can only talk for mine’.[63]

3.62In March 2023, the committee recommended in the First Report for this inquiry that the Australian Government, as part of the scheduled review of the legislation due to take place later in 2025, consider ‘the impact of the 48-hour clause on the cost of insurance premiums for Northern Australians, and the availability of insurance in the region … and adjust this clause if necessary’.[64]

3.63The Australian Government has not yet responded to the committee’s recommendation on the 48-hour rule. Treasury informed the committee at the February 2025 hearing that:

We're conscious that one of the [committee’s] recommendations relates to the 48-hour rule, so, while there hasn't been a government response, we're obviously monitoring carefully the progress of this inquiry. The minister wrote to the ARPC to conduct some modelling on that issue, which the ARPC released in September of last year. So there has been activity in relation to your work. We continue to closely monitor commentary and developments in the pool … [T]here is an upcoming review … in 2025. That will be an opportunity to more thoroughly ventilate some of the issues that have been canvassed today.[65]

3.64According to the ARPC-commissioned modelling, a change from 48 hours to 168 hours would likely cost the pool an additional $20 to $35 million per annum, with the additional cost comprising around five per cent of the pool’s current estimate of expected annual claims costs—in other words, the additional total premium that the pool would need to collect in aggregate to meet these increased costs.[66]

3.65As a result, the pool would likely need to change its premium rates and, potentially, its premium rating formula because ‘maintaining the current structure and premium rating parameters will not collect the additional premium needed to meet the increased cost’.[67]

3.66According to the modelling report, more policy holders would observe increases in their premium costs than those seeing decreases. However:

most policy holders would be offered very small increases, under $5 on average; while

policy holders benefiting from reductions would be likely to be offered much larger premium reductions, of $100 or more on average.[68]

3.67The report noted that the pool was designed to deliver the greatest benefit to the highest risk properties. Consumers in high flood risk regions, such as South East Queensland, would likely benefit the most from such a change. The report also referenced Northern New South Wales as an area subject to large exposure from cyclone-related flooding, suggesting that ‘consumers in these regions would stand to benefit the most from the increased coverage offset by modest premium increases across lower risk consumers’.[69]

3.68Mr Robb Preston from the Treasury informed the committee that if there was a large cyclone event, claims arising because of a change to 168 hours may ‘then exceed any capital buffers that ARPC has. In that case, it might lead to or increase the probability of the government guarantee to the ARPC being triggered’. In addition:

The pool is required by law to be budget neutral in expectation. The board of the ARPC would have to change the premium rates, and that would have a distributional impact. I would crudely categorise it, my take on the modelling that ARPC conducted, as saying it reduced, slightly, the benefits that are available in high-wind risk areas and [would] increase the benefits that are available in the flood areas that are brought in through the extension … What our evidence is saying is that there would not be a large amount likely of additional aggregate savings that could be distributed. Extending the pool would change how the savings are distributed.[70]

3.69The Australian Government Actuary considered that an extension to the 48-hour rule would be ‘unlikely on average to generate significant additional savings’. He did note, however, that ‘it’s a matter of judgement’ as to whether to extend the 48-hour period or not.[71]

3.70Similarly, Mr Preston from the Treasury was of the view that changing the 48-hour rule would not ‘lead to large improvements in affordability in general’. However, he believed that it would likely lead to benefits for high-risk properties and could see premium changes for some households of several hundred dollars.[72]

3.71The ARPC noted that the private reinsurance market typically provides cover for seven days overall, regardless of how long a cyclone is. The ARPC acknowledged that the current settings have created ‘some boundary issues for insurers. There is some friction around the way that they insure their flood risk’.[73]

3.72The ARPC considered that the ‘cost to the pool to increase the period is quite modest’. However, they argued that because the ‘legislation for the Cyclone Reinsurance Pool provides cover for the full duration of [a] cyclone plus an additional two days of cover’, the ‘consequence of changing that policy setting from a factual perspective is that the pool would cover a greater period of cover than would be covered in the international reinsurance markets’. In addition:

… there are risks to the public, because the pool is made up of public funds. A consequence of extending the post-cyclone cover for flood will mean that areas of low cyclone risk will have much greater coverage of flood and there will be potential unintended consequences of having to extend payments into broader areas, which could cost the public funds.

That's the reason why the legislation did try to contain the duration of the cyclone, to provide maximum savings to medium- and high-risk areas.[74]

3.73The ARPC made the following additional points on extending the 48-hour period:

The modelling was based on assumptions and projections, and actual outcomes will likely be different.

A longer period of cover would lead to more claims, with these likely to be from broader areas.

There would be an increased likelihood of the government balance sheet being drawn on for flooding in areas further from a cyclone.[75]

3.74With these caveats, the ARPC informed the committee that it ‘has the capabilities, systems and processes to be able to make that change’.[76]

3.75In January 2024, the Assistant Treasurer and Minister for Financial Services, the Hon Stephen Jones MP, stated that he had ‘an open mind’ about the 48-hour window.[77]

Footnotes

[1]Mr David Carter, Managing Director and Group Chief Executive Officer, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, p. 23.

[2]Mr Tyrone Shandiman, Australian Consumers Insurance Lobby, Committee Hansard, 7 February 2025, p. 13.

[3]Treasury Laws Amendment (Cyclone and Flood Damage Reinsurance Pool) Bill 2022, Explanatory Memorandum, p. 1.

[4]Mr Tyrone Shandiman, Chairperson, Australian Consumers Insurance Lobby, Committee Hansard, 19 April 2024, p. 26.

[5]Mr David Carter, Managing Director and Group Chief Executive Officer, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, p. 23.

[6]Mr Tyrone Shandiman, Australian Consumers Insurance Lobby, Committee Hansard, 19 April 2024, p. 26.

[7]Mr Tyrone Shandiman, Australian Consumers Insurance Lobby, Committee Hansard, 7 February 2025, p. 14.

[8]Mr Bradley Heath, Managing Director, Sure Insurance, Committee Hansard, 7 February 2025, p. 20.

[9]Australian Competition and Consumer Commission, Insurance Monitoring: Third Report Following the Introduction of a Cyclone and Cyclone-Related Flood Damage Reinsurance Pool, September 2024, p. 1.

[10]Mr David Carter, Managing Director and Group Chief Executive Officer, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, p. 25.

[11]Dr Christopher Wallace, Chief Executive Officer, Australian Reinsurance Pool Corporation, Committee Hansard, 19 April 2024, p. 38.

[12]Mr Andrew Hall, Executive Director and Chief Executive Officer, Insurance Council of Australia, Committee Hansard, 7 February 2025, pp. 1, 3. See also Mr David Carter, Managing Director and Group Chief Executive Officer, Royal Automobile Club of Queensland Limited, Committee Hansard, 19 April 2024, p. 18.

[13]Insurance Council of Australia, answers to spoken and written questions on notice from the public hearing on 7 February 2025 (received 21 February 2025), pp. 1, 2. See also Dr Christopher Wallace, Chief Executive, Australian Reinsurance Pool Corporation, Committee Hansard, 19 April 2024, p. 25.

[14]Joint Select Committee on Northern Australia, Northern Australia Workforce Development: First Report, November 2023, pp. 58–60.

[15]Northern Australia Workforce Development: Final Report, p. 149.

[16]Insurance Council of Australia, answers to spoken and written questions on notice from the public hearing on 7 February 2025 (received 21 February 2025), pp. 1, 3.

[17]Mr Andrew Huszczo, Appointed Actuary and Reinsurance Executive General Manager, Suncorp, Committee Hansard, 19 April 2024, p. 13. A ‘hard market’ refers to conditions when demand for insurance is higher than the supply.

[18]Australian Competition & Consumer Commission, Insurance Monitoring: Second Report Following the Introduction of a Cyclone and Cyclone-Related Flood Damage Reinsurance Pool, December 2023, p. 35.

[19]Mr Andrew Hall, Insurance Council of Australia, Committee Hansard, 7 February 2025, p. 2.

[20]Insurance Council of Australia, answers to spoken and written questions on notice from the public hearing on 7 February 2025 (received 21 February 2025), p. 3.

[21]Joint Select Committee on Northern Australia, First Report on the Cyclone Reinsurance Pool, March 2023, Recommendation 4, p. 60.

[22]Letter from Australian Consumers Insurance Lobby regarding marine insurance, received 28 August 2023; Letter from Marina Industries Association regarding marine insurance, received 28 August 2023; and Letter from Australian Consumers Insurance Lobby regarding the Cyclone Reinsurance Pool, received 19 September 2023.

[23]See Ms Aparna Reddy, General Manager Policy and Regulatory Affairs, Insurance Council of Australia, Committee Hansard, 25 November 2022, p. 20.

[24]Insurance Australia Group (IAG), answers to questions taken on notice - public hearing, 19 April 2024, Brisbane (received 17 May 2024), p. 2.

[25]Mr Andrew Huszczo, Suncorp, Committee Hansard, 19 April 2024, p. 16.

[26]Mr Tyrone Shandiman, Chairperson, Australian Consumers Insurance Lobby, Committee Hansard, 7 February 2025, p. 14.

[27]For example, Mr Andrew Ziolkowski, Chief Underwriting Officer, Australia Pacific, QBE Insurance Australia Ltd, Committee Hansard, 19 April 2024, p. 23.

[28]Mr Robb Preston, Assistant Secretary, Financial System Division, Department of the Treasury, Committee Hansard, 7 February 2025, p. 33.

[29]Australian Reinsurance Pool Corporation, Cyclone pool fact sheet, https://arpc.gov.au/resources/cyclone-reinsurance-pool-fact-sheet/ (accessed 18 February 2025).

[30]Townsville Chamber of Commerce, Insurance: The Market Failure of an Essential Service, tabled by Mr Andrew Willcox MP at the public hearing on 7 February 2025, p. 4.

[31]Townsville Chamber of Commerce, Insurance: The Market Failure of an Essential Service, tabled by Mr Andrew Willcox MP at the public hearing on 7 February 2025, p. 4.

[32]Mr Tyrone Shandiman, Chairperson, Australian Consumers Insurance Lobby, Committee Hansard, 19 April 2024, p. 26.

[33]Joint Select Committee on Northern Australia, First Report into the Cyclone Reinsurance Pool, March 2023, p. 63 (Recommendation 7).

[34]Ms Leisha Watson, Director, Regulatory and Consumer Policy, Committee Hansard, 7 February 2025, p. 8.

[35]Mr Michael Eady, Australian Competition and Consumer Commission, Committee Hansard, 7 February 2025, p. 29.

[36]Ms Christa Marjoribanks, Executive General Manager, Product, Pricing and Governance, Intermediated Insurance, Insurance Australia Group, Committee Hansard, 19 April 2024, p. 10.

[37]Mr James Fitzpatrick, Chief Technical Officer, Allianz Australia Limited, Committee Hansard, 19 April 2024, p. 32.

[38]Mr Tyrone Shandiman, Chairperson, Australian Consumers Insurance Lobby, Committee Hansard, 19 April 2024, p. 25.

[39]Mr Tyrone Shandiman, Chairperson, Australian Consumers Insurance Lobby, Committee Hansard, 7 February 2025, p. 11.

[40]Insurance Council of Australia, answers to spoken and written questions on notice from the public hearing on 7 February 2025 (received 21 February 2025), p. 4.

[41]Insurance Council of Australia, answers to spoken and written questions on notice from the public hearing on 7 February 2025 (received 21 February 2025), p. 4.

[42]Mr Andrew Hall, Insurance Council of Australia, Committee Hansard, 19 April 2024, pp. 3–4.

[43]Mr Andrew Huszczo, Suncorp, Committee Hansard, 19 April 2024, p. 13.

[44]Australian Reinsurance Pool Corporation, answers to written questions on notice, 12 February 2025 (received 24 February 2025), p. 7.

[45]Dr Christopher Wallace, Chief Executive Officer, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 34.

[46]Mr Bradley Heath, Sure Insurance, Committee Hansard, 7 February 2025, p. 17; Mr David Carter, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, pp. 23, 26; Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 37.

[47]Mr Guy Thorburn, Australian Government Actuary, Department of the Treasury, Committee Hansard, 7 February 2025, p. 37.

[48]Dr Christopher Wallace, Chief Executive Officer, Australian Reinsurance Pool Corporation, Committee Hansard, 19 April 2024, p. 37.

[49]Mr Andrew Hall, Insurance Council of Australia, Committee Hansard, 7 February 2025, p. 7.

[50]Mr Andrew Hall, Insurance Council of Australia, Committee Hansard, 19 April 2024, p. 3.

[51]Mr David Carter, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, p. 23.

[52]Mr Bradley Heath, Sure Insurance, Committee Hansard, 7 February 2025, p. 16.

[53]Mr David Carter, Royal Automobile Club of Queensland (RACQ), Committee Hansard, 7 February 2025, p. 23.

[54]Mr David Carter, Managing Director and Group Chief Executive Officer, Royal Automobile Club of Queensland Limited, Committee Hansard, 19 April 2024, p. 17.

[55]Mr Bradley Heath, Sure Insurance, Committee Hansard, 7 February 2025, p. 17.

[56]Mr Bradley Heath, Sure Insurance, Committee Hansard, 7 February 2025, p. 16.

[57]Mr George Karagiannakis, Insurance Australia Group, Committee Hansard, 19 April 2024, p. 7.

[58]Mr Andrew Huszczo, Suncorp, Committee Hansard, 19 April 2024, p. 12.

[59]For example, Mr Andrew Ziolkowski, QBE Insurance Australia Ltd, Committee Hansard, 19 April 2024, p. 20.

[60]First Report on the Cyclone Reinsurance Pool, March 2023, p. 42.

[61]Mr James Fitzpatrick, Chief Technical Officer, Allianz Australia Limited, Committee Hansard, 19 April 2024, p. 31.

[62]Mr James Fitzpatrick, Chief Technical Officer, Allianz Australia Limited, Committee Hansard, 19 April 2024, p. 31.

[63]Mr Bradley Heath, Sure Insurance, Committee Hansard, 7 February 2025, p. 18.

[64]First Report on the Cyclone Reinsurance Pool, March 2023, Recommendation 2, p. 59.

[65]Mr Robb Preston, Department of the Treasury, Committee Hansard, 7 February 2025, pp. 33–34.

[66]Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 34; Finity, Estimating Cyclone Pool Premiums with 168 Hour Coverage Period, September 2024, p. 2.

[67]Finity, Estimating Cyclone Pool Premiums with 168 Hour Coverage Period, September 2024, p. 2.

[68]Finity, Estimating Cyclone Pool Premiums with 168 Hour Coverage Period, September 2024, p. 2.

[69]Finity, Estimating Cyclone Pool Premiums with 168 Hour Coverage Period, September 2024, p. 2.

[70]Mr Robb Preston, Department of the Treasury, Committee Hansard, 7 February 2025, pp. 35, 36, 38.

[71]Mr Guy Thorburn, Department of the Treasury, Committee Hansard, 7 February 2025, p. 37.

[72]Mr Robb Preston, Department of the Treasury, Committee Hansard, 7 February 2025, p. 36.

[73]Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 34.

[74]Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, pp. 34–35.

[75]Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 38.

[76]Dr Christopher Wallace, Australian Reinsurance Pool Corporation, Committee Hansard, 7 February 2025, p. 35.

[77]The Hon Stephen Jones MP, Assistant Treasurer and Minister for Financial Services, Transcript: Interview with Amanda Cranston, 17 January 2024.