Matilda Seccombe and Harry Purcell
PFD Report
Partially Responded
Ref: 2025-0612
53 days overdue · 2 responses outstanding
Sent To
Response Status
Responses
5 of 7
56-Day Deadline
2 Feb 2026
53 days past deadline — 2 responses outstanding
About PFD responses
Organisations named in PFD reports must respond within 56 days explaining what actions they are taking.
Source: Courts and Tribunals Judiciary
Coroner’s Concerns
In my opinion the following concerns arise and gives rise to a continuing risk that future deaths could occur unless action is taken. A. Department for Transport (DfT)
1. The inquest noted that newly qualified drivers may carry multiple peer-age passengers immediately after passing their test. This case suggests that inexperience, peer presence and full vehicle loading can combine to elevate risk, and it is unclear how current licensing arrangements address these combined factors.
2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk. B. Driver and Vehicle Standards Agency (DVSA)
3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling. Test requirements do not involve passengers or load-related vehicle dynamics, raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving. C. Financial Conduct Authority (FCA)
4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers. Named drivers may not be subject to telematics monitoring, which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles.
5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data, or how consistently safety considerations are incorporated into insurance products designed for young drivers. D. Association of British Insurers (ABI) and Chartered Insurance Institute (CII)
6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance. E. Snap Group Limited
7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors. It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely.
8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour. There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users. F. Brake (Road-Safety Charity)
9. The circumstances of this case highlight the continued significance of peer influence, vehicle loading and rural road hazards for young drivers. It is unclear how well these risks are understood by young people, parents (particularly those organising insurance cover), or schools. G. Systemic Cross-Cutting Concerns
10. There does not appear to be a coordinated approach linking driver training bodies, insurers, social media platforms and road-safety organisations in identifying or responding to early indications of unsafe behaviour among newly qualified drivers.
1. The inquest noted that newly qualified drivers may carry multiple peer-age passengers immediately after passing their test. This case suggests that inexperience, peer presence and full vehicle loading can combine to elevate risk, and it is unclear how current licensing arrangements address these combined factors.
2. New drivers are not required to demonstrate an understanding of how passengers affect braking, stability and handling. The standard driving test does not require experience on rural roads with tight bends, undulations or variable grip. Given that collision risk is highest in the early post-test period, there is a concern as to whether current licensing arrangements adequately reflect the conditions young drivers commonly face or include a structured progression stage aligned to this risk. B. Driver and Vehicle Standards Agency (DVSA)
3. The inquest heard that newly qualified drivers may have limited experience of rural roads, vehicles under load or situations that significantly affect handling. Test requirements do not involve passengers or load-related vehicle dynamics, raising concern about whether the competencies assessed at qualification correspond to those required during the early stages of independent driving. C. Financial Conduct Authority (FCA)
4. Evidence was heard about the practice of “fronting.” Although it did not apply in this case, it illustrates difficulties insurers may face in identifying the true pattern of vehicle use when young drivers are insured as named drivers. Named drivers may not be subject to telematics monitoring, which can result in differing levels of behavioural oversight for drivers with similar early-stage risk profiles.
5. While telematics devices can monitor driving behaviour, it is unclear how insurers collect, interpret or act upon such data, or how consistently safety considerations are incorporated into insurance products designed for young drivers. D. Association of British Insurers (ABI) and Chartered Insurance Institute (CII)
6. Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety. There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance. E. Snap Group Limited
7. The inquest heard that unsafe driving behaviour was recorded and shared privately on Snapchat prior to the collision. It received no information on whether Snapchat is able to detect or review content depicting dangerous driving, including where uploaded by minors. It also remains unknown whether any such material was shared via public features, such as Spotlight or Public Stories, or whether algorithmic systems could have disseminated it more widely.
8. The filming and sharing of high-risk driving among peers, apparently treated as entertainment, raised concern that such use may normalise, encourage or reinforce risk-taking behaviour. There is no publicly available information on whether Snapchat has considered these behavioural risks or has safeguarding processes capable of identifying repeated patterns of unsafe conduct among young users. F. Brake (Road-Safety Charity)
9. The circumstances of this case highlight the continued significance of peer influence, vehicle loading and rural road hazards for young drivers. It is unclear how well these risks are understood by young people, parents (particularly those organising insurance cover), or schools. G. Systemic Cross-Cutting Concerns
10. There does not appear to be a coordinated approach linking driver training bodies, insurers, social media platforms and road-safety organisations in identifying or responding to early indications of unsafe behaviour among newly qualified drivers.
Responses
The FCA clarified its role is to regulate financial businesses and ensure fair value, not to direct road safety measures or mandate telematics use, as this falls outside its statutory remit. They expect insurers to clearly explain telematics policy features and continue to encourage the effective use of telematics data within the insurance sector.
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Dear Linda Karen Hadfield Lee,
Thank you for your email of 18 December 2025 containing your report highlighting your concerns following the two tragic deaths of teenagers in a road traffic collision. We offer our condolences to the affected families. We recognise the seriousness of the circumstances leading to these tragic deaths and provide our considered response below. FCA’s role The Financial Conduct Authority (FCA) regulates financial businesses – including insurers and insurance intermediaries, under powers granted by the Financial Services and Markets Act 2000. Our role is to ensure that markets function well, including protecting consumers and promoting effective competition in the interests of consumers. We set and enforce standards in insurance for product governance, pricing practices, and transparency, so that insurance products provide fair value and firms deliver good outcomes for customers in line with their Consumer Duty obligations (the Duty). As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.
Motor insurance and the role of telematics Motor insurance provides financial protection for motorists against loss or damage, and to indemnify other road users or members of the public for loss or damage for which they are liable. The core purpose of insurance is to manage financial risk, not to prevent accidents. Telematics motor insurance policies – sometimes referred to as “black box” insurance – use technology to monitor driving behaviour and usage patterns. This enables insurers to offer premiums to policyholders based on actual risk rather than using demographic averages. There can be important wider benefits from telematics where it leads to more careful driving and fewer accidents, including those resulting in death or injury. Recent data from Mintel shows that telematics-based policies account for around 14% of all UK motor insurance policies. In addition, the Government’s analysis within the Motor Insurance Taskforce Report published in December 2025, highlights that although drivers may be aware of the benefits of telematics policies, uptake remains low. It is also possible to include named drivers in telematics policies and the named driver’s driving behaviour is likely to impact the premiums of the main policyholder. We expect insurers to ensure any key product features and limitations are clearly explained so that customers understand these, including how their driving data from telematics could impact their premiums. Mandating telematics for all new young drivers (including new young named drivers) could have a material effect on pricing of motor insurance, potentially restricting consumer choice. It could, for example, disadvantage those without compatible technology or those financially constrained, making insurance unaffordable for some, and potentially increasing uninsured driving. Any consideration of the desirability or otherwise of making telematics mandatory for the purposes of reducing accidents and/or improving driving standards falls outside our remit. Fronting We also take the opportunity to comment on the practice of ‘fronting’ mentioned in your report, albeit noting that it did not apply in this case. ‘Fronting’ is the practice of naming a person as main driver for the purpose of obtaining a lower premium, on behalf of a different person (usually a young driver). A person knowingly obtaining insurance on this basis is committing a fraud which, if discovered, can lead to serious penalties. The Insurance Fraud Bureau, an industry-funded body, works with the police and insurance industry to combat this and other fraudulent practices.
Next steps We have carefully considered the matters raised in your report. While we cannot act beyond our statutory remit, we remain committed to ensuring that firms meet the highest standards under our existing rules. We continue to encourage effective and appropriate use of telematics data in the insurance sector.
Thank you for your email of 18 December 2025 containing your report highlighting your concerns following the two tragic deaths of teenagers in a road traffic collision. We offer our condolences to the affected families. We recognise the seriousness of the circumstances leading to these tragic deaths and provide our considered response below. FCA’s role The Financial Conduct Authority (FCA) regulates financial businesses – including insurers and insurance intermediaries, under powers granted by the Financial Services and Markets Act 2000. Our role is to ensure that markets function well, including protecting consumers and promoting effective competition in the interests of consumers. We set and enforce standards in insurance for product governance, pricing practices, and transparency, so that insurance products provide fair value and firms deliver good outcomes for customers in line with their Consumer Duty obligations (the Duty). As we are not the competent authority for matters concerning driver or road safety, we cannot direct insurers in these areas, such as requiring specific product features or mandating the use of telematics. Those decisions sit with the Government through primary legislation.
Motor insurance and the role of telematics Motor insurance provides financial protection for motorists against loss or damage, and to indemnify other road users or members of the public for loss or damage for which they are liable. The core purpose of insurance is to manage financial risk, not to prevent accidents. Telematics motor insurance policies – sometimes referred to as “black box” insurance – use technology to monitor driving behaviour and usage patterns. This enables insurers to offer premiums to policyholders based on actual risk rather than using demographic averages. There can be important wider benefits from telematics where it leads to more careful driving and fewer accidents, including those resulting in death or injury. Recent data from Mintel shows that telematics-based policies account for around 14% of all UK motor insurance policies. In addition, the Government’s analysis within the Motor Insurance Taskforce Report published in December 2025, highlights that although drivers may be aware of the benefits of telematics policies, uptake remains low. It is also possible to include named drivers in telematics policies and the named driver’s driving behaviour is likely to impact the premiums of the main policyholder. We expect insurers to ensure any key product features and limitations are clearly explained so that customers understand these, including how their driving data from telematics could impact their premiums. Mandating telematics for all new young drivers (including new young named drivers) could have a material effect on pricing of motor insurance, potentially restricting consumer choice. It could, for example, disadvantage those without compatible technology or those financially constrained, making insurance unaffordable for some, and potentially increasing uninsured driving. Any consideration of the desirability or otherwise of making telematics mandatory for the purposes of reducing accidents and/or improving driving standards falls outside our remit. Fronting We also take the opportunity to comment on the practice of ‘fronting’ mentioned in your report, albeit noting that it did not apply in this case. ‘Fronting’ is the practice of naming a person as main driver for the purpose of obtaining a lower premium, on behalf of a different person (usually a young driver). A person knowingly obtaining insurance on this basis is committing a fraud which, if discovered, can lead to serious penalties. The Insurance Fraud Bureau, an industry-funded body, works with the police and insurance industry to combat this and other fraudulent practices.
Next steps We have carefully considered the matters raised in your report. While we cannot act beyond our statutory remit, we remain committed to ensuring that firms meet the highest standards under our existing rules. We continue to encourage effective and appropriate use of telematics data in the insurance sector.
The ABI noted its role as a representative body and detailed its past advocacy for telematics integration in a government taskforce. As next steps, it commits to continuing to promote telematics, advocate for young driver safety, collaborate with road safety partners, and campaign against insurance frauds.
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The ABI’s Response to The Coroner’s Office, Coventry and Warwickshire: Regulation 28 Report to Prevent Future Deaths
05.02.2026
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
About us The ABI is the definitive voice of the UK’s world-leading insurance and long-term savings industry, which is the largest sector in Europe and the third largest in the world. We are not a regulator, nor do we have powers to compel insurers to conduct their operations in specific ways. We represent more than 300 firms within our membership including most household names and specialist providers, providing peace of mind to customers across the UK. Our sector is productive, inclusive and essential to the UK economy and together, we are driving change to protect and build a thriving society. Find out more at abi.org.uk
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
The ABI’s Response to The Coroner’s Office, Coventry and Warwickshire: Regulation 28 Report to Prevent Future Deaths The ABI would like to express our deepest condolences to the families and friends of Harry Purcell, Matilda Seccombe, and all those affected by the tragic events of 21 April 2023.
We have carefully considered the Coroner’s detailed Report of 8 December 2025 and, in preparing this response, hope that we have addressed the concerns raised regarding the role of the insurance sector in helping to prevent future deaths.
We note the specific issues identified in section D of the Report, concerning industry practices around named driver arrangements, telematics adoption, and the communication of safety-related aspects of telematics to young drivers and their families. We also wanted to share information on how the wider motor insurance industry supports young drivers and improved road safety measures.
Industry support for young drivers and road safety The primary purpose of motor insurance is to provide financial protection to vehicle owners for damage caused to their own vehicle, or damage or injury they cause to others. A minimum of third-party motor insurance is a legal requirement to drive on UK roads. The ABI is actively engaging with its insurer members through our Motor Insurance Roadmap to support young drivers, and we continue to advocate for progressive policy change at the government level. We strongly welcome the Government’s recent Road Safety Strategy and endorse several key measures designed to protect young and novice drivers, as well as the wider public. The motor insurance industry also invests in and advocates for improved road safety to prevent accidents from occurring. This includes:
• Graduated Driving Licences / Progressive Driving Licence: The industry supports the introduction of phased driving licences, where new drivers gradually gain experience under lower- risk conditions. This system may include restrictions such as limits on carrying passengers, reduced alcohol limits, or engine size restrictions for a set period. The aim is to reduce risks for newly qualified drivers and encourage safer habits as they build experience.
• Telematics-based Insurance: Insurers offer telematics (or ‘black box’) policies that use technology to monitor driving behaviour, such as speed, braking, cornering, and the times of day the vehicle is used. Good driving is rewarded with lower premiums, while risky behaviour may result in higher costs, thereby incentivising safer driving, especially among young drivers.
• Road Safety Education and Campaigns: The industry invests in public awareness campaigns and educational initiatives—often in partnership with road safety charities—to inform drivers about the dangers of speeding, drink-driving, mobile phone use, and other risky behaviours.
• Collaboration with Government and Stakeholders: Insurers work closely with government bodies, police, and road safety organisations to advocate for policy changes and support national strategies aimed at reducing road accidents, such as supporting minimum learning periods and improved driving tests.
• Data Analysis and Research: By analysing accident data, claims trends, and emerging risks, the industry helps identify problem areas and inform both policy and product development, contributing to evidence-based improvements in road safety.
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
• Product and Vehicle Innovation: Development of insurance products that reward safe driving behaviour, such as no-claims discounts and incentives for installing advanced safety features or using telematics, further encourages safer driving. Additionally, insurers fund and support the work of Thatcham Research, the UK’s automotive research centre, to enhance vehicle safety standards. Thatcham Research leads in testing and promoting advanced safety technologies and crash prevention measures, helping to make vehicles safer for all road users.
Industry Practice: Named Driver Arrangements The ABI recognises the critical importance of accurately assessing risk, particularly in relation to young and newly qualified drivers, who unfortunately statistically face a higher likelihood of being involved in road traffic incidents. The buyer of the motor insurance policy should correctly declare the main user of the insured vehicle, as this helps insurers determine the level of risk associated with each policyholder. This practice is designed to prevent misrepresentation, known as “fronting”, where a more experienced driver is listed as the main policyholder, but a younger or riskier driver predominantly uses the vehicle. While we acknowledge that fronting was not a factor in this tragic accident, we have outlined below the steps that insurers take to help mitigate it.
While there is currently no single, industry-wide methodology for identifying higher-than-expected use by named drivers, this is because it can be difficult to identify, and insurers are, to an extent, reliant on the honesty of their policyholders. Nevertheless, insurers do employ a range of tools and data sources to detect potential fronting, including analysing patterns of vehicle usage, monitoring claims histories, reviewing telematics data, and looking for inconsistencies in declared information. For instance, insurers might flag policies where a named driver appears to be using the vehicle far more frequently than the main policyholder, or where telematics data suggests driving habits do not match the profile of the declared main user.
Telematics: Application and Communication Telematics technology has become a vital tool in promoting safer driving among young motorists, providing real-time feedback and incentivising positive driving behaviours. However, the use of telematics remains optional for motorists, and neither the ABI nor its members have the authority to mandate its adoption. Requiring telematics for all drivers could limit consumer choice and potentially increase the cost of cover for some individuals. Nevertheless, the ABI is committed to working with its members to continue championing the benefits of telematics, encouraging its uptake among new and novice drivers to help improve road safety.
In addition to our work with insurers, the ABI collaborates with leading road safety charities, including BRAKE, RoSPA, and PACTS, to further strengthen our approach to telematics and its role in young driver safety. These partnerships enable us to draw upon expert knowledge and outreach capabilities to ensure that communications about telematics are both accurate and impactful, particularly in highlighting its potential to reduce risky driving behaviours and prevent accidents.
Furthermore, our engagement with the Department for Transport is central to these efforts. The ABI participated in the Stakeholder Panel of the Government’s recent Motor Insurance Taskforce, where we advocated for the integration of telematics data into broader road safety initiatives.
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
Through these collaborative actions, we aim to support insurers in explaining the role of telematics—not only as a tool for premium calculation, but also as a way to enhance road safety for young drivers and the wider community.
Next Steps As part of our established workstreams and priorities, the ABI will:
• Continue to work with our members to promote the use of telematics products for young and novice drivers.
• Continue to advocate for young and novice driver safety to the Government as part of the Road Safety Strategy, including progressive licensing.
• Continue to collaborate with road safety partners and government to promote awareness of the risks faced by young drivers, and support broader initiatives to reduce road traffic fatalities among this group.
• Continue to campaign to raise awareness amongst young drivers of motor insurance frauds, such as fronting and ghost broking, working alongside stakeholders, including the Driver and Vehicle Standards Agency.
We are committed to supporting the prevention of further tragedies and to playing our part in supporting safer outcomes for young drivers on the UK’s roads.
For further information about our work or to discuss these actions in more detail, please contact the ABI through
05.02.2026
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
About us The ABI is the definitive voice of the UK’s world-leading insurance and long-term savings industry, which is the largest sector in Europe and the third largest in the world. We are not a regulator, nor do we have powers to compel insurers to conduct their operations in specific ways. We represent more than 300 firms within our membership including most household names and specialist providers, providing peace of mind to customers across the UK. Our sector is productive, inclusive and essential to the UK economy and together, we are driving change to protect and build a thriving society. Find out more at abi.org.uk
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
The ABI’s Response to The Coroner’s Office, Coventry and Warwickshire: Regulation 28 Report to Prevent Future Deaths The ABI would like to express our deepest condolences to the families and friends of Harry Purcell, Matilda Seccombe, and all those affected by the tragic events of 21 April 2023.
We have carefully considered the Coroner’s detailed Report of 8 December 2025 and, in preparing this response, hope that we have addressed the concerns raised regarding the role of the insurance sector in helping to prevent future deaths.
We note the specific issues identified in section D of the Report, concerning industry practices around named driver arrangements, telematics adoption, and the communication of safety-related aspects of telematics to young drivers and their families. We also wanted to share information on how the wider motor insurance industry supports young drivers and improved road safety measures.
Industry support for young drivers and road safety The primary purpose of motor insurance is to provide financial protection to vehicle owners for damage caused to their own vehicle, or damage or injury they cause to others. A minimum of third-party motor insurance is a legal requirement to drive on UK roads. The ABI is actively engaging with its insurer members through our Motor Insurance Roadmap to support young drivers, and we continue to advocate for progressive policy change at the government level. We strongly welcome the Government’s recent Road Safety Strategy and endorse several key measures designed to protect young and novice drivers, as well as the wider public. The motor insurance industry also invests in and advocates for improved road safety to prevent accidents from occurring. This includes:
• Graduated Driving Licences / Progressive Driving Licence: The industry supports the introduction of phased driving licences, where new drivers gradually gain experience under lower- risk conditions. This system may include restrictions such as limits on carrying passengers, reduced alcohol limits, or engine size restrictions for a set period. The aim is to reduce risks for newly qualified drivers and encourage safer habits as they build experience.
• Telematics-based Insurance: Insurers offer telematics (or ‘black box’) policies that use technology to monitor driving behaviour, such as speed, braking, cornering, and the times of day the vehicle is used. Good driving is rewarded with lower premiums, while risky behaviour may result in higher costs, thereby incentivising safer driving, especially among young drivers.
• Road Safety Education and Campaigns: The industry invests in public awareness campaigns and educational initiatives—often in partnership with road safety charities—to inform drivers about the dangers of speeding, drink-driving, mobile phone use, and other risky behaviours.
• Collaboration with Government and Stakeholders: Insurers work closely with government bodies, police, and road safety organisations to advocate for policy changes and support national strategies aimed at reducing road accidents, such as supporting minimum learning periods and improved driving tests.
• Data Analysis and Research: By analysing accident data, claims trends, and emerging risks, the industry helps identify problem areas and inform both policy and product development, contributing to evidence-based improvements in road safety.
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
• Product and Vehicle Innovation: Development of insurance products that reward safe driving behaviour, such as no-claims discounts and incentives for installing advanced safety features or using telematics, further encourages safer driving. Additionally, insurers fund and support the work of Thatcham Research, the UK’s automotive research centre, to enhance vehicle safety standards. Thatcham Research leads in testing and promoting advanced safety technologies and crash prevention measures, helping to make vehicles safer for all road users.
Industry Practice: Named Driver Arrangements The ABI recognises the critical importance of accurately assessing risk, particularly in relation to young and newly qualified drivers, who unfortunately statistically face a higher likelihood of being involved in road traffic incidents. The buyer of the motor insurance policy should correctly declare the main user of the insured vehicle, as this helps insurers determine the level of risk associated with each policyholder. This practice is designed to prevent misrepresentation, known as “fronting”, where a more experienced driver is listed as the main policyholder, but a younger or riskier driver predominantly uses the vehicle. While we acknowledge that fronting was not a factor in this tragic accident, we have outlined below the steps that insurers take to help mitigate it.
While there is currently no single, industry-wide methodology for identifying higher-than-expected use by named drivers, this is because it can be difficult to identify, and insurers are, to an extent, reliant on the honesty of their policyholders. Nevertheless, insurers do employ a range of tools and data sources to detect potential fronting, including analysing patterns of vehicle usage, monitoring claims histories, reviewing telematics data, and looking for inconsistencies in declared information. For instance, insurers might flag policies where a named driver appears to be using the vehicle far more frequently than the main policyholder, or where telematics data suggests driving habits do not match the profile of the declared main user.
Telematics: Application and Communication Telematics technology has become a vital tool in promoting safer driving among young motorists, providing real-time feedback and incentivising positive driving behaviours. However, the use of telematics remains optional for motorists, and neither the ABI nor its members have the authority to mandate its adoption. Requiring telematics for all drivers could limit consumer choice and potentially increase the cost of cover for some individuals. Nevertheless, the ABI is committed to working with its members to continue championing the benefits of telematics, encouraging its uptake among new and novice drivers to help improve road safety.
In addition to our work with insurers, the ABI collaborates with leading road safety charities, including BRAKE, RoSPA, and PACTS, to further strengthen our approach to telematics and its role in young driver safety. These partnerships enable us to draw upon expert knowledge and outreach capabilities to ensure that communications about telematics are both accurate and impactful, particularly in highlighting its potential to reduce risky driving behaviours and prevent accidents.
Furthermore, our engagement with the Department for Transport is central to these efforts. The ABI participated in the Stakeholder Panel of the Government’s recent Motor Insurance Taskforce, where we advocated for the integration of telematics data into broader road safety initiatives.
The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026
Through these collaborative actions, we aim to support insurers in explaining the role of telematics—not only as a tool for premium calculation, but also as a way to enhance road safety for young drivers and the wider community.
Next Steps As part of our established workstreams and priorities, the ABI will:
• Continue to work with our members to promote the use of telematics products for young and novice drivers.
• Continue to advocate for young and novice driver safety to the Government as part of the Road Safety Strategy, including progressive licensing.
• Continue to collaborate with road safety partners and government to promote awareness of the risks faced by young drivers, and support broader initiatives to reduce road traffic fatalities among this group.
• Continue to campaign to raise awareness amongst young drivers of motor insurance frauds, such as fronting and ghost broking, working alongside stakeholders, including the Driver and Vehicle Standards Agency.
We are committed to supporting the prevention of further tragedies and to playing our part in supporting safer outcomes for young drivers on the UK’s roads.
For further information about our work or to discuss these actions in more detail, please contact the ABI through
The Department for Transport published a new Road Safety Strategy in January 2026 and the DVSA launched the 'Ready to Pass' campaign in July 2022. They also advise learner drivers and instructors on test readiness and encourage varied lesson conditions. A consultation on a Minimum Learning Period for learner drivers is currently open, with responses to be published later.
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Dear Linda Karen Hadfield Lee,
RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE DEATHS
Thank you for your letter of 18 December 2025, enclosing your Regulation 28 Report to Prevent Future Deaths dated 8 December 2025 made under the Coroners and Justice Act 2009 and the Coroners (Investigations) Regulations 2013, following the inquest you conducted into the deaths of Harry Jospeh Purcell and Matilda ‘Tilly’ Grace Seccombe.
I am deeply saddened by the circumstances of the deaths of Harry Purcell, Tilly Seccombe, and Frank Wormald, and I would like to extend my sincere condolences to their families.
I am responding on behalf of two of the addressees of your report, the Department for Transport and its executive agency the Driver and Vehicle Standards Agency (“DVSA”).
Improving road safety is one of my Department’s highest priorities. Too many people are killed and seriously injured in road traffic collisions, and this Government will work hard to prevent these tragedies for all road users.
The latest statistics do show that the number of car fatalities involving 17 to 24-year-olds on Britain’s roads is falling – from 448 in 1990 to 73 in 2024. This is an 84% total decrease. However, this Government acknowledges that there is still work to be done. In terms of population and the number of miles driven, 17– 24-year-olds, particularly young men, remain one of the highest fatality risk groups both as car drivers and passengers.
That is one reason why, on 7 January 2026 my Department published a new Road Safety Strategy, setting out the Government’s vision for a safer future on our roads for all. The Strategy sets an ambitious target to reduce the number of people killed or seriously injured on British roads by 65% by 2035. This target will focus the efforts of road safety partners across Britain, with measures to improve road design, protect vulnerable road users, and review motoring offences. All of this will be supported and monitored by a new Road Safety Board which I will chair.
Whilst we are not considering further restrictions on newly qualified drivers such as carrying passengers or driving at night, we are consulting on a Minimum Learning Period in England, Scotland, and Wales before learner drivers can take their practical driving test.
As part of our consultation into a Minimum Learning Period, we are asking about including a mandatory modular syllabus as part of the new mandatory learner requirements. Learner drivers are already encouraged to gain experience in a range of driving conditions as part of their learning journey. This includes practice during nighttime, on rural and urban roads, in poor weather and on higher-speed roads. Exposure to varied scenarios helps learners develop competence, adaptability and preparedness for real-world driving. A modular learning syllabus could formalise this approach by requiring structured experience across diverse conditions. We know from research carried out in other countries that introducing a “Minimum Learning Period” has potential to reduce the number of deaths and serious injuries.
This is why we are consulting on the introduction of pre-test measures and combining these with the post-test measures already in place through the Road Traffic (New Drivers) Act 1995. That Act has a form of “probationary period” of 2 years for novice drivers of all ages in Great Britain. During this time, instead of the standard 12 points, if 6 or more points are received, including in the learning period, a driver's licence is revoked and they must apply again for a provisional licence, re-entering the learning stage.
Additionally, as part of the motoring offences consultation, we are consulting on a lower blood alcohol limit for novice drivers in England and Wales. Turning to the concerns raised regarding the scope of the current driving test: the object of the driving test is to ensure that the candidate is well grounded in the basic principles of safe driving and is sufficiently practised in them to be able to show, at the time of the test, that they are a competent and considerate driver and are not a source of danger to themselves or to other road users. If a candidate reaches the required standard they will pass their test. However, it is not intended to, and could not, replicate every scenario a driver may encounter after qualification.
The driving test has been continually reviewed and has undergone many changes over the years, which includes adding the sat nav for the independent driving. This is to ensure that it is fit for purpose for today’s roads and meets current legislative and road safety requirements. The test remains under constant review. Following a successful five-month trial, the DVSA introduced updates to the car practical driving test from Monday 24 November 2025. As a result of these changes, learner drivers will spend more time on higher-speed roads during their driving test, where location allows. These changes aim to enhance road safety, address collision rates in rural areas and align the test more closely with real-world driving conditions. Reviewing and refreshing all current routes will take time. The expectation is that by 31 March 2026, each Driving Test Centre will have reviewed and updated all routes to be more relevant and to include high speed, high risk rural roads where location allows. Vehicle loading and passenger dynamics are important aspects of safe driving, but these situations vary significantly depending on vehicle type and usage. For this reason, the test focuses on core competencies such as hazard perception, vehicle control, and decision-making, which are fundamental to adapting safely to different conditions. Learner drivers have the option to carry passengers during their learning journeys. The theory test includes questions on vehicle handling and loading to help learner drivers understand the key road safety considerations involved. DVSA promotes ‘Pass Plus’, which is a practical training course that takes at least 6 hours and is for drivers to improve their skills and drive more safely. It can be taken at any time although it should be most useful to new drivers in the year after passing their test. Pass Plus training takes at least 6 hours. It has 6 modules, covering driving:
• in town
• in all weathers
• on rural roads
• at night
• on dual carriageways
• on motorways
Some motor insurance companies offer discounts for drivers who complete the ‘Pass Plus’ scheme. DVSA produces a number of guidance documents to assist drivers, including the ‘Highway Code’, ‘The Official DVSA Guides to Driving – the essential skills’ and ‘The Official DVSA Guide to Riding – the essential skills’. Further information on these guidance documents can be viewed via the following links -
The Official DVSA Guide to Driving - the essential skills The Official DVSA Guide to Riding - the essential skills DVSA advises learner drivers and Approved Driving Instructors (ADIs) to ensure that candidates for a driving test are sufficiently prepared and ready to drive independently and sit a driving test. The Ready to Pass campaign was launched in July 2022. The campaign targets learners, their parents, and driving instructors in Great Britain. It aims to improve learners’ understanding of what it means to be test ready and how they can assess their readiness. The campaign also advises to delay a test if an individual is not ready.
DVSA encourages the ADI industry to take lessons in different weather conditions and on rural and urban roads as well as motorways. In addition, the DVSA encourages ADIs to provide learner drivers with a mock driving test, that takes place on a variety of roads, including rural roads with higher speed limits and dual carriageways with the national speed limit.
I want to reiterate that this Government treats road safety seriously, and we are committed to reducing the numbers of those killed and injured on our roads. The consultation on introducing a Minimum Learning Period for learner drivers closes on 11 May and can be found at the following link:
learning-period-for-learner-drivers/introducing-a-minimum-learning-period-for- learner-drivers-category-b-driving-licence Once this and other road safety consultations have concluded, we will publish our responses in due course.
Best wishes,
MINISTER FOR LOCAL TRANSPORT
RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE DEATHS
Thank you for your letter of 18 December 2025, enclosing your Regulation 28 Report to Prevent Future Deaths dated 8 December 2025 made under the Coroners and Justice Act 2009 and the Coroners (Investigations) Regulations 2013, following the inquest you conducted into the deaths of Harry Jospeh Purcell and Matilda ‘Tilly’ Grace Seccombe.
I am deeply saddened by the circumstances of the deaths of Harry Purcell, Tilly Seccombe, and Frank Wormald, and I would like to extend my sincere condolences to their families.
I am responding on behalf of two of the addressees of your report, the Department for Transport and its executive agency the Driver and Vehicle Standards Agency (“DVSA”).
Improving road safety is one of my Department’s highest priorities. Too many people are killed and seriously injured in road traffic collisions, and this Government will work hard to prevent these tragedies for all road users.
The latest statistics do show that the number of car fatalities involving 17 to 24-year-olds on Britain’s roads is falling – from 448 in 1990 to 73 in 2024. This is an 84% total decrease. However, this Government acknowledges that there is still work to be done. In terms of population and the number of miles driven, 17– 24-year-olds, particularly young men, remain one of the highest fatality risk groups both as car drivers and passengers.
That is one reason why, on 7 January 2026 my Department published a new Road Safety Strategy, setting out the Government’s vision for a safer future on our roads for all. The Strategy sets an ambitious target to reduce the number of people killed or seriously injured on British roads by 65% by 2035. This target will focus the efforts of road safety partners across Britain, with measures to improve road design, protect vulnerable road users, and review motoring offences. All of this will be supported and monitored by a new Road Safety Board which I will chair.
Whilst we are not considering further restrictions on newly qualified drivers such as carrying passengers or driving at night, we are consulting on a Minimum Learning Period in England, Scotland, and Wales before learner drivers can take their practical driving test.
As part of our consultation into a Minimum Learning Period, we are asking about including a mandatory modular syllabus as part of the new mandatory learner requirements. Learner drivers are already encouraged to gain experience in a range of driving conditions as part of their learning journey. This includes practice during nighttime, on rural and urban roads, in poor weather and on higher-speed roads. Exposure to varied scenarios helps learners develop competence, adaptability and preparedness for real-world driving. A modular learning syllabus could formalise this approach by requiring structured experience across diverse conditions. We know from research carried out in other countries that introducing a “Minimum Learning Period” has potential to reduce the number of deaths and serious injuries.
This is why we are consulting on the introduction of pre-test measures and combining these with the post-test measures already in place through the Road Traffic (New Drivers) Act 1995. That Act has a form of “probationary period” of 2 years for novice drivers of all ages in Great Britain. During this time, instead of the standard 12 points, if 6 or more points are received, including in the learning period, a driver's licence is revoked and they must apply again for a provisional licence, re-entering the learning stage.
Additionally, as part of the motoring offences consultation, we are consulting on a lower blood alcohol limit for novice drivers in England and Wales. Turning to the concerns raised regarding the scope of the current driving test: the object of the driving test is to ensure that the candidate is well grounded in the basic principles of safe driving and is sufficiently practised in them to be able to show, at the time of the test, that they are a competent and considerate driver and are not a source of danger to themselves or to other road users. If a candidate reaches the required standard they will pass their test. However, it is not intended to, and could not, replicate every scenario a driver may encounter after qualification.
The driving test has been continually reviewed and has undergone many changes over the years, which includes adding the sat nav for the independent driving. This is to ensure that it is fit for purpose for today’s roads and meets current legislative and road safety requirements. The test remains under constant review. Following a successful five-month trial, the DVSA introduced updates to the car practical driving test from Monday 24 November 2025. As a result of these changes, learner drivers will spend more time on higher-speed roads during their driving test, where location allows. These changes aim to enhance road safety, address collision rates in rural areas and align the test more closely with real-world driving conditions. Reviewing and refreshing all current routes will take time. The expectation is that by 31 March 2026, each Driving Test Centre will have reviewed and updated all routes to be more relevant and to include high speed, high risk rural roads where location allows. Vehicle loading and passenger dynamics are important aspects of safe driving, but these situations vary significantly depending on vehicle type and usage. For this reason, the test focuses on core competencies such as hazard perception, vehicle control, and decision-making, which are fundamental to adapting safely to different conditions. Learner drivers have the option to carry passengers during their learning journeys. The theory test includes questions on vehicle handling and loading to help learner drivers understand the key road safety considerations involved. DVSA promotes ‘Pass Plus’, which is a practical training course that takes at least 6 hours and is for drivers to improve their skills and drive more safely. It can be taken at any time although it should be most useful to new drivers in the year after passing their test. Pass Plus training takes at least 6 hours. It has 6 modules, covering driving:
• in town
• in all weathers
• on rural roads
• at night
• on dual carriageways
• on motorways
Some motor insurance companies offer discounts for drivers who complete the ‘Pass Plus’ scheme. DVSA produces a number of guidance documents to assist drivers, including the ‘Highway Code’, ‘The Official DVSA Guides to Driving – the essential skills’ and ‘The Official DVSA Guide to Riding – the essential skills’. Further information on these guidance documents can be viewed via the following links -
The Official DVSA Guide to Driving - the essential skills The Official DVSA Guide to Riding - the essential skills DVSA advises learner drivers and Approved Driving Instructors (ADIs) to ensure that candidates for a driving test are sufficiently prepared and ready to drive independently and sit a driving test. The Ready to Pass campaign was launched in July 2022. The campaign targets learners, their parents, and driving instructors in Great Britain. It aims to improve learners’ understanding of what it means to be test ready and how they can assess their readiness. The campaign also advises to delay a test if an individual is not ready.
DVSA encourages the ADI industry to take lessons in different weather conditions and on rural and urban roads as well as motorways. In addition, the DVSA encourages ADIs to provide learner drivers with a mock driving test, that takes place on a variety of roads, including rural roads with higher speed limits and dual carriageways with the national speed limit.
I want to reiterate that this Government treats road safety seriously, and we are committed to reducing the numbers of those killed and injured on our roads. The consultation on introducing a Minimum Learning Period for learner drivers closes on 11 May and can be found at the following link:
learning-period-for-learner-drivers/introducing-a-minimum-learning-period-for- learner-drivers-category-b-driving-licence Once this and other road safety consultations have concluded, we will publish our responses in due course.
Best wishes,
MINISTER FOR LOCAL TRANSPORT
Brake campaigns for stronger licensing measures for young drivers, delivers road safety education, and coordinates Road Safety Week. They will also be releasing research on young drivers shortly and will continue to use their platforms to raise awareness of road safety issues.
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Dear Ms Lee, Re: Regulation 28 Report to Prevent Future Deaths
I am writing in response to the Regulation 28 Prevention of Future Deaths report issued on 8 December 2025 concerning the tragic deaths of Matilda (Tilly) Grace Seccombe and Harry Joseph Purcell. On behalf of Brake, I extend our deepest condolences to the families, friends, and communities affected by the deaths of Tilly and Harry. We recognise the profound trauma and grief caused by this tragedy, and we offer our sincere sympathy to everyone impacted. We also wish to commend you for your thorough investigation and for issuing a Prevention of Future Deaths (PFD) report. Such reports play a vital role in identifying risks and prompting action to reduce the likelihood of further loss of life. Your report highlights the significance of peer influence, vehicle loading, and rural road hazards for young drivers, and identifies uncertainty around how well these risks are understood by young people, parents (particularly those arranging insurance cover), and schools. These are important issues that require continued consideration at national level. Brake is a national road-safety charity. We campaign for evidence-based policies that prevent road deaths and injuries, raise awareness of key risks, and provide specialist support for people bereaved and seriously injured in road crashes. We have long campaigned for stronger licensing measures to protect young and newly qualified drivers, and this remains one of our organisational priorities. We partner with the Protect Young Drivers campaign, and we will shortly be releasing research undertaken last year on this issue. I will ensure a copy is shared with you once published. Education and awareness-raising are also central to our work. Brake has delivered road-safety education for many years, including initiatives in primary schools, and we coordinate Road Safety Week each November. We note the new National Road Safety Strategy’s emphasis on a lifelong learning approach and the government's commitment to publishing national guidance and a supporting manual for road-safety education. We welcome this focus and will follow its development closely.
PO Box 18,896 Sutton Coldfield B73 9BL
Chief executive:
Trustees:
Brake is a company limited by guarantee with charitable objectives Registered in the UK No. 3260243 Registered Charity No. 1093244
Alongside our campaigning and education work, we operate the National Road Victim Service, providing specialist emotional and practical support to families bereaved and seriously injured in road crashes. In 2025, we supported more than 2,000 families. The trauma we witness every day reinforces the urgency of effective prevention measures. Brake will continue to use our voice and our platforms to raise important issues such as those identified in your report. We do so on behalf of all families devastated by road crashes, with a commitment to doing all we can to prevent future tragedies and reduce harm where crashes still occur.
I am writing in response to the Regulation 28 Prevention of Future Deaths report issued on 8 December 2025 concerning the tragic deaths of Matilda (Tilly) Grace Seccombe and Harry Joseph Purcell. On behalf of Brake, I extend our deepest condolences to the families, friends, and communities affected by the deaths of Tilly and Harry. We recognise the profound trauma and grief caused by this tragedy, and we offer our sincere sympathy to everyone impacted. We also wish to commend you for your thorough investigation and for issuing a Prevention of Future Deaths (PFD) report. Such reports play a vital role in identifying risks and prompting action to reduce the likelihood of further loss of life. Your report highlights the significance of peer influence, vehicle loading, and rural road hazards for young drivers, and identifies uncertainty around how well these risks are understood by young people, parents (particularly those arranging insurance cover), and schools. These are important issues that require continued consideration at national level. Brake is a national road-safety charity. We campaign for evidence-based policies that prevent road deaths and injuries, raise awareness of key risks, and provide specialist support for people bereaved and seriously injured in road crashes. We have long campaigned for stronger licensing measures to protect young and newly qualified drivers, and this remains one of our organisational priorities. We partner with the Protect Young Drivers campaign, and we will shortly be releasing research undertaken last year on this issue. I will ensure a copy is shared with you once published. Education and awareness-raising are also central to our work. Brake has delivered road-safety education for many years, including initiatives in primary schools, and we coordinate Road Safety Week each November. We note the new National Road Safety Strategy’s emphasis on a lifelong learning approach and the government's commitment to publishing national guidance and a supporting manual for road-safety education. We welcome this focus and will follow its development closely.
PO Box 18,896 Sutton Coldfield B73 9BL
Chief executive:
Trustees:
Brake is a company limited by guarantee with charitable objectives Registered in the UK No. 3260243 Registered Charity No. 1093244
Alongside our campaigning and education work, we operate the National Road Victim Service, providing specialist emotional and practical support to families bereaved and seriously injured in road crashes. In 2025, we supported more than 2,000 families. The trauma we witness every day reinforces the urgency of effective prevention measures. Brake will continue to use our voice and our platforms to raise important issues such as those identified in your report. We do so on behalf of all families devastated by road crashes, with a commitment to doing all we can to prevent future tragedies and reduce harm where crashes still occur.
The CII commits to writing to Corporate Chartered insurance firms and working with industry stakeholders to stimulate greater prioritisation of young drivers, consistency in identifying named driver misuse, and improved promotion and use of telematics data for road safety. They plan to complete a consultation by June 2026 and publish guidance by the end of 2026.
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Response to the Coroner’s Office of Coventry and Warwickshire’s Regulation 28 Report to Prevent Future Deaths Harry Joseph Purcell, Deceased and Matilda (Tilly) Grace Seccombe, Deceased
Chartered Insurance Institute Response
Chartered Insurance Institute Response to The Coroner’s Office of Coventry and Warwickshire’s Regulation 28 Report
1. Key Points
We would like to express our sadness over the deaths of Harry Purcell and Tilly Seccombe, and we would like to thank the Coroner for inviting us to help develop a practical approach to improving road safety.
We have also noted the article published by the BBC in which Harry’s mother, , called for the more effective adoption of telematics for young drivers.1 As a profession, we are determined to find ways to avoid tragedies such as this from happening in future. The issues the Coroner has asked us to consider are:
• Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety.
• There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance.”
• In response to these findings, the CII (Chartered Insurance Institute) commits to:
• Write to all general insurance firms that have been awarded Corporate Chartered status by the CII,2 to highlight the publication of the Regulation 28 report and the issues that it raises.
• Work with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the FCA (Financial Conduct Authority) to stimulate: o higher prioritisation of young drivers as potentially vulnerable customers,
1 BBC (2025), Show off driver who killed three teens sentenced at:
2 See https://www.cii.co.uk/membership/join-us/chartered/ for more information about Chartered status, including Corporate Chartered status.
o greater consistency in the way insurers apply good practice when identifying ‘fronting’ (the misuse of named driver arrangements), o greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, and o greater consistency in the way insurers apply good practice to the use of telematics data.
• The guidance will identify: o the most effective methods for influencing behavioural change in younger drivers, and o the most effective operational processes for proactive risk management, including the way in which data can be collected, interpreted and acted upon.
• The CII commits to completing a consultation period of four months, to June 2026, and publishing guidance by the end of 2026.
2. Background to our response
2.1 Telematics and their impact on road safety Adoption of telematics rose to an estimated 1.66 million policies in 2022. Over a similar period, between 2004 and 2024, casualties fell almost 40% faster among younger drivers compared to older drivers:
• KSI (killed or seriously injured) casualties from a collision involving at least one younger car driver (aged between 17 and 24) decreased from 12,190 to 4,740, a fall of 61%
• KSI casualties in collisions involving other aged car drivers decreased from 30,967 to 19,368, a fall of 37%3
2.2 Market incentives for telematics Insurers have used pricing to incentivise younger drivers to adopt telematics. According to the research firm, Consumer Intelligence, among drivers between the ages of 17-19, ‘83% find telematics cheaper, with median savings of £2,172 (116% difference)’ From ages 25-29, those considering telematics drops to 51%, as no-claims discounts reduce the cost of traditional insurance, and from age 35, those considering telematics falls below 25%.4
2.3 Option to introduce a self-regulatory approach to adopting telematics A purely self-regulatory approach to forcing more drivers to adopt telematics is unlikely to work.
3 Department for Transport (2025) Reported road casualties in Great Britain: younger driver factsheet at: Reported road casualties in Great Britain: younger driver factsheet, 2024 - GOV.UK 4 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at:
penalty-forces-young-drivers-into-surveillance
There are two reasons for this:
• First, a market agreement (for example, an agreement between insurers to only offer insurance with telematics to drivers under a certain age) could easily be undermined by some insurance firms opting out of the agreement and appealing to customers who want traditional insurance. These firms would benefit from the significant proportion of drivers who dislike the reduction in privacy that comes with telematics (for example, a recent survey by telematics provider IMS showed that 62% of UK motorists were worried about sharing their personal location information).5
• Second, the greatest benefits of telematics can only be derived from a range of measures. For example, the research agency, Consumer Intelligence, has summarised some of these approaches as: o ‘Reframe Year One: Position telematics as a "Recognised Driver Journey"
– a fast-track to trusted status, not probation o ‘Change the Language: Replace "we monitor" with "you demonstrate" o ‘Provide Real Control: Let customers choose what aspects of driving they want to showcase o ‘Create Lasting Value: Offer permanent recognition status that follows them even if they switch insurers’ Consumer Intelligence concluded, ‘Insurers need to stop selling surveillance and start selling recognition. Our research shows customers who feel recognised and in control have three times higher voluntary adoption rates.’ 6 As a result, prescriptive approaches based on mandating the kind of technology used or the kind of communication given to drivers are unlikely to be the best route to securing safer driving.
5 IMS (2026) Personalised pricing uptake to flatline in 2026 unless UK-based insurers address privacy concerns at
insurers-address-privacy-concerns/ 6 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at:
penalty-forces-young-drivers-into-surveillance
2.4 Option to treat younger drivers as vulnerable customers Although mandating technology or communications in a self-regulating environment may not be the best option to promote safer driving, the FCA approach to vulnerability may provide a better mechanism to secure more uniform adoption of good practice. The FCA’s approach to vulnerability requires financial services firms to adopt reasonable adjustments for groups of consumers who may be at greater risk of harm as a result of ‘drivers of vulnerability’. These ‘drivers’ are:
• Low financial capacity
• Low financial resilience
• Life events
• Illness and disability The approach requires insurers to address the risks of vulnerability through a process of monitoring consumer behaviour, analysing and learning from the resulting data, and adjusting the firm’s proposition to improve outcomes.7 There is a strong argument that young drivers and their families are more vulnerable than other motor insurance customers, because:
• Being a new driver is a life event that carries risks – since new drivers are less aware of the risks of driving, and their families are likely to be less aware of the risks of committing fraud through ‘fronting’.
• New drivers have lower levels of financial capability than other motor customers, because they are less likely to have experience of repeat purchases of motor insurance.
• New drivers often have lower levels of financial resilience, which may increase safety risks (for example, if they are not able to afford vehicles with non- compulsory safety features). There is also a strong argument that insurers should develop an approach to younger drivers that will help them to overcome these risks, for example through:
• Better consumer understanding of the risks involved with being a new driver.
• Better consumer understanding of the benefits of telematics.
7 Financial Conduct Authority (2021) FG21/1 Guidance for firms on the fair treatment of vulnerable customers at FG21/1: Guidance for firms on the fair treatment of vulnerable customers and Financial Conduct Authority (2022) FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty at FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty
• Better product governance, including being more willing to refuse insurance to younger drivers who pose a significant risk.8
2.5 CII Commitments The CII commits to encouraging the insurance community to consider younger drivers as potentially vulnerable consumers through:
• Developing guidance for the profession on the aspects of new drivers that makes them more vulnerable. The CII has recently published guidance for members on vulnerability (Managing customer vulnerability in insurance and personal finance: A practical implementation guide) that explores how vulnerability can be put into practice through the effective use of leadership, systems, data management and training, with a particular emphasis on effective data management. We will build on these insights when producing the guidance.9
• Working with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the Financial Conduct Authority to build on existing good practice (such as the BIBA Good practice guide to selling telematics10) to stimulate: o higher prioritisation of young drivers as potentially vulnerable customers o greater consistency in the way insurers apply good practice when identifying the misuse of named driver arrangements o greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, o greater consistency in the way insurers apply good practice in the use of telematics data to improve road safety. In doing so, we will focus on factors identified by telematics providers are areas for improvement, including:
• Methods for influencing behavioural change in customers
• Operational processes for proactive risk management, including the way in which data can be collected, interpreted and acted upon.11 The CII commits to completing a consultation period of four months, to June 2026, and publishing guidance by the end of 2026.
8 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/ 9 Chartered Insurance Institute (2025) Managing customer vulnerability in insurance and personal finance: A practical implementation guide at Managing customer vulnerability in insurance and personal finance: A practical implementation guide 10 BIBA (2022) Good practice guide to selling telematics at: https://www.biba.org.uk/technical-updates/good- practice-guide-to-selling-telematics/ 11 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/
Chartered Insurance Institute Response
Chartered Insurance Institute Response to The Coroner’s Office of Coventry and Warwickshire’s Regulation 28 Report
1. Key Points
We would like to express our sadness over the deaths of Harry Purcell and Tilly Seccombe, and we would like to thank the Coroner for inviting us to help develop a practical approach to improving road safety.
We have also noted the article published by the BBC in which Harry’s mother, , called for the more effective adoption of telematics for young drivers.1 As a profession, we are determined to find ways to avoid tragedies such as this from happening in future. The issues the Coroner has asked us to consider are:
• Industry practice does not appear to include a consistent method for identifying when a named driver arrangement may conceal higher-than-expected use by a young driver, with implications for risk assessment and safety.
• There is also no uniform approach to how telematics is applied or the need for its use communicated to young drivers. The inquest noted uncertainty about how clearly insurers and brokers explain the safety-related aspects of telematics to young drivers or their families, which may influence decisions made when arranging insurance.”
• In response to these findings, the CII (Chartered Insurance Institute) commits to:
• Write to all general insurance firms that have been awarded Corporate Chartered status by the CII,2 to highlight the publication of the Regulation 28 report and the issues that it raises.
• Work with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the FCA (Financial Conduct Authority) to stimulate: o higher prioritisation of young drivers as potentially vulnerable customers,
1 BBC (2025), Show off driver who killed three teens sentenced at:
2 See https://www.cii.co.uk/membership/join-us/chartered/ for more information about Chartered status, including Corporate Chartered status.
o greater consistency in the way insurers apply good practice when identifying ‘fronting’ (the misuse of named driver arrangements), o greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, and o greater consistency in the way insurers apply good practice to the use of telematics data.
• The guidance will identify: o the most effective methods for influencing behavioural change in younger drivers, and o the most effective operational processes for proactive risk management, including the way in which data can be collected, interpreted and acted upon.
• The CII commits to completing a consultation period of four months, to June 2026, and publishing guidance by the end of 2026.
2. Background to our response
2.1 Telematics and their impact on road safety Adoption of telematics rose to an estimated 1.66 million policies in 2022. Over a similar period, between 2004 and 2024, casualties fell almost 40% faster among younger drivers compared to older drivers:
• KSI (killed or seriously injured) casualties from a collision involving at least one younger car driver (aged between 17 and 24) decreased from 12,190 to 4,740, a fall of 61%
• KSI casualties in collisions involving other aged car drivers decreased from 30,967 to 19,368, a fall of 37%3
2.2 Market incentives for telematics Insurers have used pricing to incentivise younger drivers to adopt telematics. According to the research firm, Consumer Intelligence, among drivers between the ages of 17-19, ‘83% find telematics cheaper, with median savings of £2,172 (116% difference)’ From ages 25-29, those considering telematics drops to 51%, as no-claims discounts reduce the cost of traditional insurance, and from age 35, those considering telematics falls below 25%.4
2.3 Option to introduce a self-regulatory approach to adopting telematics A purely self-regulatory approach to forcing more drivers to adopt telematics is unlikely to work.
3 Department for Transport (2025) Reported road casualties in Great Britain: younger driver factsheet at: Reported road casualties in Great Britain: younger driver factsheet, 2024 - GOV.UK 4 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at:
penalty-forces-young-drivers-into-surveillance
There are two reasons for this:
• First, a market agreement (for example, an agreement between insurers to only offer insurance with telematics to drivers under a certain age) could easily be undermined by some insurance firms opting out of the agreement and appealing to customers who want traditional insurance. These firms would benefit from the significant proportion of drivers who dislike the reduction in privacy that comes with telematics (for example, a recent survey by telematics provider IMS showed that 62% of UK motorists were worried about sharing their personal location information).5
• Second, the greatest benefits of telematics can only be derived from a range of measures. For example, the research agency, Consumer Intelligence, has summarised some of these approaches as: o ‘Reframe Year One: Position telematics as a "Recognised Driver Journey"
– a fast-track to trusted status, not probation o ‘Change the Language: Replace "we monitor" with "you demonstrate" o ‘Provide Real Control: Let customers choose what aspects of driving they want to showcase o ‘Create Lasting Value: Offer permanent recognition status that follows them even if they switch insurers’ Consumer Intelligence concluded, ‘Insurers need to stop selling surveillance and start selling recognition. Our research shows customers who feel recognised and in control have three times higher voluntary adoption rates.’ 6 As a result, prescriptive approaches based on mandating the kind of technology used or the kind of communication given to drivers are unlikely to be the best route to securing safer driving.
5 IMS (2026) Personalised pricing uptake to flatline in 2026 unless UK-based insurers address privacy concerns at
insurers-address-privacy-concerns/ 6 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at:
penalty-forces-young-drivers-into-surveillance
2.4 Option to treat younger drivers as vulnerable customers Although mandating technology or communications in a self-regulating environment may not be the best option to promote safer driving, the FCA approach to vulnerability may provide a better mechanism to secure more uniform adoption of good practice. The FCA’s approach to vulnerability requires financial services firms to adopt reasonable adjustments for groups of consumers who may be at greater risk of harm as a result of ‘drivers of vulnerability’. These ‘drivers’ are:
• Low financial capacity
• Low financial resilience
• Life events
• Illness and disability The approach requires insurers to address the risks of vulnerability through a process of monitoring consumer behaviour, analysing and learning from the resulting data, and adjusting the firm’s proposition to improve outcomes.7 There is a strong argument that young drivers and their families are more vulnerable than other motor insurance customers, because:
• Being a new driver is a life event that carries risks – since new drivers are less aware of the risks of driving, and their families are likely to be less aware of the risks of committing fraud through ‘fronting’.
• New drivers have lower levels of financial capability than other motor customers, because they are less likely to have experience of repeat purchases of motor insurance.
• New drivers often have lower levels of financial resilience, which may increase safety risks (for example, if they are not able to afford vehicles with non- compulsory safety features). There is also a strong argument that insurers should develop an approach to younger drivers that will help them to overcome these risks, for example through:
• Better consumer understanding of the risks involved with being a new driver.
• Better consumer understanding of the benefits of telematics.
7 Financial Conduct Authority (2021) FG21/1 Guidance for firms on the fair treatment of vulnerable customers at FG21/1: Guidance for firms on the fair treatment of vulnerable customers and Financial Conduct Authority (2022) FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty at FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty
• Better product governance, including being more willing to refuse insurance to younger drivers who pose a significant risk.8
2.5 CII Commitments The CII commits to encouraging the insurance community to consider younger drivers as potentially vulnerable consumers through:
• Developing guidance for the profession on the aspects of new drivers that makes them more vulnerable. The CII has recently published guidance for members on vulnerability (Managing customer vulnerability in insurance and personal finance: A practical implementation guide) that explores how vulnerability can be put into practice through the effective use of leadership, systems, data management and training, with a particular emphasis on effective data management. We will build on these insights when producing the guidance.9
• Working with insurers, trade associations, road safety groups, driver training bodies, consumer groups and the Financial Conduct Authority to build on existing good practice (such as the BIBA Good practice guide to selling telematics10) to stimulate: o higher prioritisation of young drivers as potentially vulnerable customers o greater consistency in the way insurers apply good practice when identifying the misuse of named driver arrangements o greater consistency in the way insurers apply good practice in the promotion of telematics to young drivers, o greater consistency in the way insurers apply good practice in the use of telematics data to improve road safety. In doing so, we will focus on factors identified by telematics providers are areas for improvement, including:
• Methods for influencing behavioural change in customers
• Operational processes for proactive risk management, including the way in which data can be collected, interpreted and acted upon.11 The CII commits to completing a consultation period of four months, to June 2026, and publishing guidance by the end of 2026.
8 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/ 9 Chartered Insurance Institute (2025) Managing customer vulnerability in insurance and personal finance: A practical implementation guide at Managing customer vulnerability in insurance and personal finance: A practical implementation guide 10 BIBA (2022) Good practice guide to selling telematics at: https://www.biba.org.uk/technical-updates/good- practice-guide-to-selling-telematics/ 11 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/
Action Should Be Taken
In my opinion action should be taken to prevent future deaths by addressing the concerns set out above and I believe your organisation has the power to take such action.
Report Sections
Investigation and Inquest
These inquests were resumed following the conclusion of criminal proceedings in which the driver of the vehicle was convicted of causing death by careless driving and causing serious injury by careless driving. The driver was sentenced to a detention in a Young Offender Institution (DYOI) sentence for twenty four months and disqualified from driving for eight years. With the criminal process concluded, the inquest proceeded to consider the circumstances of the two deaths and concluded on the 4 December 2025 when I found that the medical cause of death was: In respect of Harry: I (a) Head and Neck Injuries In respect of Tilly: I (a) Head injury and my conclusion as to the death for both deaths was: Road Traffic Collision
Circumstances of the Death
The fatal collision occurred on 21 April 2023 shortly after 4.08 pm on a rural, single-carriageway road, the B4035 near the Portobello crossroads in Shipston-on-Stour. Three passengers, aged 16 and 17, sustained fatal injuries. The driver, aged 17, had passed his driving test only a matter of weeks earlier on 10 March 2023. A second vehicle was struck, and its occupants were seriously injured. The road featured sharp bends, an undulating surface, “SLOW” markings and chevron signage warning of severe curves. Weather and visibility were clear. The vehicle was travelling at excessive speed, inappropriate for the road layout and the presence of several young passengers. The vehicle was fully loaded. Expert evidence indicated that loss of control was consistent with lift-off oversteer, occurring when the driver realised too late that he had entered the bend at excessive speed and lifted off the accelerator. His corrective actions were ineffective, causing the vehicle to cross into the path of an oncoming car. Prior to the collision, Tilly had expressed concern to friends about the driver’s manner of driving, concerns of which her parents were unaware at the time. The driver did not heed these concerns. Snapchat clips were located showing the driver engaging in unsafe driving behaviour in the weeks after passing his test, including excessive speed on rural roads, filming or commenting while driving, a relaxed one-handed driving posture, and trivialising near misses. These clips were shared within a private group. It is unknown whether any content was also shared via Snapchat’s public features. The driver was described as a habitual bad driver, showing off, driving too fast, and displaying a very poor attitude to speed. The inquest also heard brief evidence about “fronting.” This did not apply in this case; the driver was correctly insured as a named driver. As named drivers are not routinely subject to telematics monitoring, the policy did not provide external oversight that might have identified or discouraged emerging unsafe driving behaviours in the early post-test period.
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Data sourced from Courts and Tribunals Judiciary under the Open Government Licence.