The Bank of France published an opinion adopted by the Consultative Committee for the Financial Sector, or CCSF, on mortgage borrower insurance contracts. It sets out insurer commitments intended to eliminate coverage gaps when borrowers switch insurer, clarify access to policies sold without medical underwriting under the Lemoine law, and make key guarantees easier to compare and understand. The opinion responds to issues identified after the 2022 Lemoine law broadened switching rights and barred health questions or medical exams for certain mortgage loans where the insured share does not exceed EUR 200,000 per borrower and repayment ends before age 60. Since then, substitution requests rose from 198,530 in 2021 to 496,654 in 2024, the acceptance rate for substitutions reached nearly 94%, and the market share of external alternative insurers increased to 17.48% from 16%. To address remaining frictions, the original insurer would continue to cover a claim declared before substitution and its immediate consequences, including disability following an uninterrupted work stoppage, while the new insurer would cover a relapse after the switch. Insurers also proposed to assess the EUR 200,000 threshold only by reference to the insured share of outstanding mortgage loans within the scope of the Consumer Code. The CCSF said exclusions for pre-existing medical conditions in policies sold without medical underwriting are not consistent with the objective of the Lemoine law. On contract readability, insurers proposed common reference thresholds of 66% for permanent total disability and 33% for permanent partial disability, clearer disclosure of the functional incapacity scale and disability-rate calculation, assessment of occupational incapacity against the policyholder's actual job at the time of loss, and treatment of generic death cover as covering all causes unless expressly limited to accidental death. Insurers proposed to apply the continuity measures from Sept. 1, 2026, with generalization by Jan. 1, 2027. The clarified interpretation of the EUR 200,000 threshold would start on Sept. 1, 2026, with generalization by June 1, 2027. The contract clarity measures would apply to new business from Sept. 1, 2026, and be generalized for all new business written after June 1, 2027. The CCSF said it will review how the opinion is being applied after implementation, including monitoring pricing and claims experience by 2028.
Bank of France2026-06-24
Bank of France publishes CCSF opinion on mortgage borrower insurance continuity and contract clarity
The Bank of France published a CCSF opinion on mortgage borrower insurance that sets out insurer commitments to prevent coverage gaps when policies are switched, clarify eligibility for medical-free cover under the Lemoine law, and standardize key contract terms. The CCSF also said pre-existing-condition exclusions in policies sold without medical underwriting do not align with the law's objective. Implementation is proposed from Sept. 1, 2026, with broader rollouts through June 1, 2027, and a follow-up review by 2028.