Review of the Code of Practice by Forvis Mazars


Independent Review confirms success of Insurance Ireland Code of Practice for Underwriting Mortgage Protection Insurance for Cancer Survivors with mortgage protection policies now available to more cancer survivors without increased cost and with a more streamlined application process 

  • Insurance Ireland Life Members implemented a Code of Practice for Underwriting Mortgage Protection Insurance for Cancer Survivors in December 2023.
  • Independent Forvis Mazars review conducted among the eight insurance companies who signed up shows that all are adhering to the Code.
  • The Code means that insurers have undertaken to disregard a cancer diagnosis disclosure if treatment ended more than 7 years prior to application or more than 5 years if the applicant was under 18 at the time of diagnosis.

26 May 2025.  An independent review of the implementation of the Code of Practice for Underwriting Mortgage Protection Insurance for Cancer Survivors, introduced in December 2023, reveals positive outcomes. The independent review, conducted by Forvis Mazars, found that mortgage protection policies are now available to more cancer survivors without increased cost and with a streamlined application process.  The implementation of the Code in December 2023 followed discussions with the Irish Cancer Society.  Under the Code, which applies to applications for policies for a mortgage on a principal private residence, the eight insurers who have signed up are:

  • fully adhering to the Code;
  • disregarding a cancer diagnosis disclosure if treatment ended more than 7 years prior to application or more than 5 years if the applicant was under 18 at the time of diagnosis;
  • offering cover of up to €500,000 per applicant. Data from Insurance Ireland members shows that over 90% of mortgage protection policies in Ireland are below €500,000, which means that the vast majority of mortgage applicants will be applying for mortgage cover below this amount.

The independent Forvis Mazars report, commissioned by Insurance Ireland, found no breaches of the Code and states that where a cancer diagnosis is disclosed, all firms assess the application against the Code parameters and where the requirements are met, the application follows the provisions of the Code.  The independent review found that the Code of Practice was applied to all applicants who met the criteria.  Mortgage protection products are now available to more cancer survivors without increased cost and with a streamlined application process. The report also found that for some cancer survivors the cost of their mortgage protection policy did not change (as they would have been offered standard premiums prior to the introduction of the Code). However, these cancer survivors also benefited from a quicker application process.

The eight life insurance companies signed up to the Code, and who took part in the review are: 

  • Acorn Life DAC 
  • Aviva Life & Pensions Ireland DAC 
  • Irish Life Assurance plc 
  • Laya Life (IptiQ Life SA) 
  • New Ireland Assurance Company plc 
  • Royal London Insurance DAC 
  • Saol Assurance dac (AIB Life) 
  • Zurich Life Assurance plc

Speaking about the independent review by Forvis Mazars, Moyagh Murdock, Chief Executive, Insurance Ireland, said “Insurance Ireland and its members took on board the Irish Cancer Society’s concerns regarding the challenges cancer survivors faced and sought to alleviate them for the Irish Cancer Society and the cancer survivors they represent.  This independent report shows that the Code is being implemented fully and insurers are playing their part in resolving this issue for people who are already experiencing great challenge in their lives.  We are delighted to see that the Code is working so well in practice and we look forward to working constructively with Government in that regard to legislate for the Code of Practice for Underwriting Mortgage Protection Insurance, in line with their commitment in the Programme for Government.”

Commenting on the release of the independent review, Minister of State for Financial Services, Credit Unions and Insurance Robert Troy, said: “The data in the Insurance Ireland report on the Voluntary Code of Practice clearly shows that a level playing field is possible when it comes to mortgage protection for cancer survivors. I welcome the industry’s efforts to align with the Code. My focus now turns to ensuring that the ‘Right to be Forgotten’ is robustly legislated for. This is a clear Programme for Government commitment, and I look forward to seeing it enacted in the early stages of this Government.”

Murdock also highlighted the sector’s ongoing support for those diagnosed with cancer, saying “in 2023, the Irish life insurance sector paid €557.2m in life insurance claims, €253.8m of which specifically related to cancer. The Irish life insurance sector has been dedicated to assisting those who receive a cancer diagnosis for many years and is pleased to now be assisting cancer survivors through the application of the Code.”

Ends

You can find the full text of the review here: External Review of the Insurance Ireland Code of Practice

Notes to Editor

Background

Insurance Ireland Code of Practice for Underwriting Mortgage Protection Insurance for Cancer Survivors

Insurers will disregard any disclosed cancer diagnosis where all of the following circumstances apply. An application for decreasing term assurance in association with a mortgage will not be rejected, nor will a higher premium apply, in relation to the cancer condition, if:

    • The application is for a for new individual decreasing term life insurance contracts covering the risk of death only. Applications for other insurance benefits or other policies to provide an income or payment in the event of ill-health or accident are not included.
    • The application is for a policy in connection with a mortgage on the applicant’s principal private residence. A principal private residence is where the applicant lives most or all of the time. This includes first time buyers, home movers and re-mortgages but not second homes or buy to let mortgages. 
  • The amount of life insurance is the lesser of the mortgage amount OR €500,000 per applicant.
  • Treatment for cancer ended more than 7 years prior to their application or more than 5 years if the applicant was under 18 at the time of diagnosis.

Exemption from the requirement for Life Cover when Applying for a Mortgage

There may unfortunately be instances where no insurer can offer life cover.  When this happens, and specialist advisers cannot source an alternative, it does not mean that cancer survivors cannot get a mortgage. There is an exemption from this requirement in the Consumer Credit Act 1995 that states that lenders can waive this requirement where:

  • the applicant is over 50 years old; or
  • loans to people who belong to a group who would not be acceptable to an insurer or would only be acceptable to an insurer at a premium significantly higher than that payable by borrowers generally.

The granting of this waiver is at the discretion of the lender. If a customer is declined a mortgage due to a lack of life cover, they should seek advice from their lender or their broker/financial adviser about this.  

Data from the Banking and Payments Federation of Ireland obtained by the Minister for Finance in October 2021 estimates that, on an annual basis, 2% of mortgage approvals to consumers have been granted a waiver, and only 0.05% of mortgage applications approved by its members did not proceed to draw-down due to a lack of mortgage protection insurance.

Specialist Support for Customers

It is important that applicants can access specialist support in understanding which insurers can offer the most appropriate cover and most suitable approach to underwriting for each applicant’s specific circumstances. Brokers Ireland host a register of intermediaries who specialise in recommending appropriate cover for cancer survivors.

The Conclusion of the External Review of the Insurance Ireland Code of Practice for Underwriting Mortgage Protection Insurance for Cancer Survivors was:

The Code of Practice was applied to all applicants who met the criteria, and many who did not benefited from the introduction of the Code. 

Mortgage protection products are now available to more cancer survivors without increased cost and with a streamlined application process.

For some cancer survivors the cost of their mortgage protection policy did not change (as they would have been offered standard premiums prior to the introduction of the Code of Practice). However, these cancer survivors also benefited from a quicker application process.

Media contact:

Nuala Buttner

Q4 Public Relations

+353 (0)85 1744275