We need an insurance market, which is offering products which are fit for today, and fit for the future as well, and that includes Build Back Better, which is a world first innovation from Flood Re.
Dermot Kehoe
Communications and
Transition Director
View bio
Launching the Transition Plan
In June 2023, Flood Re launched its third Transition Plan, setting out our approach to exiting the insurance market in 2039.
The plan was the culmination of extensive engagement with stakeholders across the insurance industry, Government and those involved in flood management. It was grounded in our assessment of what needs to be true in order for flood insurance to remain widely available and affordable when we exit; and our Theory of Change as to how we can maximise the chances of these changes occurring. The Plan outlines our key commitments for the next five years.
The Transition Plan was launched on the top of the Gherkin in London’s financial district, with an event hosted by meteorologist Laura Tobin, and with speeches from Flood Re’s Chair and CEO as well as Dame Diana Johnson MP.
The availability of flood insurance in a post-Flood Re market will depend on progress being made across three areas, which Flood Re terms ‘buckets’:

Within this there are a wide range of drivers and determinants, mostly outside of Flood Re’s direct control. Since 2020, Flood Re has used a set of indicators to track progress on each of these issues. As part of our wider commitment to transparency, each year Flood Re updates our assessment of these indicators to set-out our view as to whether sufficient progress is being made in each of the three buckets below to ensure flood insurance remains widely available post-2039
While the 2024 update does include some positive developments, the most significant developments this year have been negative. Inflation is the biggest issue, resulting in a significant downturn on the returns on investment in flood defences and huge rises in the costs of flood claims. At the same time progress at reducing climate change seems to be insufficient and a high-number of natural catastrophes around the world, most likely linked to climate change, means that the costs of reinsurance – which UK insurers would need to purchase in a market without Flood Re – have risen sharply.
Bucket one
Reducing the risk of flooding
The first bucket is focused on macro factors most heavily influenced by the policies and programs of senior governments, and hence an area where Flood Re’s work tries to influence rather than deliver. The combined impacts of climate change and inflation have led to a notable deterioration in the long-term prospects for flood risk management in the UK. In 2023 world temperatures were – across the year – 1.5⁰C higher than pre-industrial times for the first time. In England, the impact of inflation means that record investment in flood defences is likely to deliver 40% less than originally planned. Because of this downward revision to the numbers of properties protected, the first indicator has shifted to the left, while the second and third remained unchanged, resulting in a slight move to the left for the bucket overall.
Dial key:
Indicator one
Investing in flood risk management and defences
In England, the Government is spending £5.2bn in flood defences from 2021-2027. This represents a 54% real-terms increase in funding compared with the period 2015-21. However, in November 2023, the National Audit Office (NAO) published an investigation into the Environment Agency’s flood defence spending and found that the current funding round is set to achieve 40% less than anticipated in terms of the number of homes better protected, in particular due to cost inflation reducing the number of potential projects.
The National Audit Office also raised concerns about a lack of clarity as to overall progress in reducing flood risk and concluded: “the Environment Agency has set out short-term actions in its roadmap to 2026 but these are not sufficient to achieve its long-term objectives to 2050, and it has not yet established any plans or milestones to bridge the gap”. This is similar to concerns raised by the National Infrastructure Commission’s Infrastructure Progress Review 2024 about progress on flood resilience not being achieved due to a lack of long-term target setting, lack of strategic approach and implementation of supportive policies to manage surface water flooding.
A lack of equivalent data makes it hard to track progress in Scotland, Wales and Northern Ireland.
Indicator two
Development with flood risk in mind
The latest statistics show that in England 7% of new residential addresses were in Flood Zone 3, which is described as “the Environment Agency’s best estimate of the areas of land at risk of flooding, when the presence of flood defences are ignored and covers land with a 1 in 100 (1%) or greater chance of flooding each year from Rivers; or with a 1 in 200 (0.5%) or greater chance of flooding each year from the Sea.”
The National Infrastructure Commission has recommended the Government update planning guidance to “require planning authorities to ensure that from 2026 all new development is resilient to flooding from rivers with an annual likelihood of 0.5 per cent for its lifetime and does not increase risk elsewhere”.
Indicator three
Adapting to climate change
In 2023, world temperatures were – across the year – 1.5⁰C higher than pre-industrial times for the first time. Alongside this, atmospheric CO2 concentrations reached a new peak in 2023 and are projected to continue to rise in 2024. Emissions globally are currently trending slightly above the RCP 2.6 pathway (which would mean achievement of the Paris Climate Change Agreement to limit global warming to 1.5⁰C) and the RCP 4.5 (which would mean missing them), but there is still time to implement policies to avert the worst implications of climate change. But limiting warming to even 2°C at this stage will require rapid, deep and in most cases immediate greenhouse emission reductions which are not being seen globally. Global temperature rises above 1.5⁰C would make it significantly more difficult – and expensive – for the UK to adapt to global warming.
The third National Adaptation Programme was published in July of 2023, representing the Government’s overarching national adaptation strategy, which is updated every five years. The assessment of the Office for Environmental Protection in its 2024 annual progress report is that: “The Third National Adaptation Programme published in 2023 represents some progress on previous plans, however many actions can be found in previous strategies and there is very little new funding, indicating a lack of ambition to keep pace with growing climate risks”. Overall they rated progress in this area as ‘Limited’ (Red).
Bucket two
Reducing the damage and costs of flooding
The second bucket contains areas where Flood Re is active, including through BBB, as well as collaborating with community and local partners. Last year’s assessment was that there were an increasing number of programs being implemented to help householders reduce their flood risk, but that this was not yet sufficient to keep pace with costs and damages. This trend has accelerated this year, with more adaptation support available, but also costs associated with floods rising rapidly due to inflation. Flood Re’s Build Back Better Scheme went live in April 2023 and has seen more and more insurers committing to the Scheme. In England, the Environment Agency has expanded its framework to allow more homes to receive PFR. However, increases in the costs of raw materials, labour shortages in the construction sector and a lack of temporary accommodation have all contributed to significant rise in the costs caused by flooding. Flood Re has seen a 44% increase in the average cost of a claim between Storms Ciara and Denis in 2021 and Storm Babet in 20231. Analysis undertaken by Flood Re and Verisk estimates that UK insurers will pay out £2bn to repair flooded homes in the UK over the next five years. While most indicators in this bucket remain unchanged, indictor 8 (costs) shifted significantly to the left because of spiraling inflation/costs, which more than offset slight positives in the community preparedness and home resilience buckets, resulting in a more negative indicator than last year.
1 Note this figure is reflecting of properties ceded to Flood Re and will be influenced by the types of homes flooded in each storm.
Dial key:
Indicator four
Improving flood resilience products
Build Back Better went live in 2023/24, significantly increasing the demand for flood resilience products in the UK. The Environment Agency launched its second PFR framework this year (see Indicator 5), which embedded mechanisms for property evaluation and assurance of installation. These helped to sustain the market for flood resilience products after years in which a limited market saw companies leaving the market. No new products achieved certification to the British Standard in the last year, and although there were no reports of product shortages, a tight market for PFR products gave rise to higher reported costs.
Indicator five
Improving the overall resilience of the UK’s housing
The updated Environment Agency PFR Framework anticipates a doubling of PFR installations over the coming 3-year framework, from 300-500 to approximately 1000+ homes per year over the cycle (although this is dependent on decisions by regional EA offices and Local Authorities). The new framework envisages spending of up to £125M, compared to £25M under the previous framework.
In the last 12 months, Build Back Better has been formally launched with insurers committing to the program and commencing delivery, 75% of the insurance market now offer BBB. Overall, the number of homes receiving PFR went from around 500 last year, to upwards of 1250 this year, showing a positive upwards trajectory.
Indicator six
Improving community flood preparedness and resilience
A greater number of initiatives this year aimed to make householders aware of risks, and a high number of floods garnered considerable media attention. Flood Re partnered with the EA to launch a ‘Be Flood Smart’ campaign aimed at educating householders about how they could reduce their flood risk. The campaign used innovative approaches to inform people about what they could do and achieved over 12m social media impressions. The Environment Agency has also increased engaged, their 2023 update stated that they expanded flood alerts to an additional 180 communities and 110,000 homes, and recent storms drove significant further sign-ups. But a poll undertaken for Flood Re to inform the ‘Be Flood Smart’ campaign identified the underlying levels of flood risk knowledge with just 24% of respondents at ‘high’ flood risk correctly identifying their risk.
Indicator seven
Minimising the cost of reinstatement
The cost of reinstating a home after flooding is dependent on the costs of material, labour and alternative accommodation. In 2023, the costs of the rebuild levelled off after a 20% rise in 2022, but record increases in the costs of rented accommodation, meant that overall flood claims continue to rise.
Taken together, the rebuild cost rises that occurred during 2021, and the continuing increases in rental costs, mean there has been a significant rise in the overall cost of flood claims. Flood Re has seen a 44% increase in the average cost of a claim between Storms Ciara and Denis in 2021 and Storm Babet in 20231, awaiting final cost figure from discussion with ABI/actuaries. Analysis undertaken by Flood Re and Verisk estimates that UK insurers will pay out £2bn to repair flooded homes in the UK over the next five years. This – and the rising premium costs noted in the next bucket – show insurers need to be doing more to contain costs.
1 Note this figure is reflecting of properties ceded to Flood Re and will be influenced by the types of homes flooded in each storm.
Bucket three
Achieving an effective market
The market factors in the third bucket are a combination of areas influenced primarily by insurers and the private sector (#8 and #11), broad collaborations (#10) and the functioning of the Flood Re Scheme (#9), highlighting the multi-faceted nature of the insurance market. Last year, Flood Re rated the outlook in this area as slightly negative, with positives such as good flood modelling and insurer engagement balanced by negative metrics on consumer information. This year, developments in the market, particularly the escalating cost of premiums and a fall in the number of home insurance premiums sold, continues this trend. The escalating cost of obtaining reinsurance for natural catastrophe perils means it would be much more expensive for insurers to provide flood cover in a market without Flood Re.
Most of this bucket remained unchanged, but the increased cost of insurance in the UK (and reinsurance globally) created slight pressure to the left, offsetting positives like growing BBB participation.
Dial key:
Indicator eight
Improved quality and use of flood models
A scoping exercise undertaken to inform Flood Re’s ‘Homes, Floods, and Insurance Hub’ found that the UK is generally seen as a world leader in flood modelling and mapping. Yet more needs to be done to ensure timely updates and inclusion of flood defences in commercial flood maps and models, to reflect the current state of risks. The next year should see a major step forward in terms of publicly available integrated flood modelling for England through the long-awaited NAFRA2/National Flood Risk Assessment 2, due to be published late 2024. This map should combine surface water with other risk types, and enable significantly more detailed information, including on projected depth, to be available to householders. Flood Re is not aware of plans to publish equivalent detail in Scotland, Wales or Northern Ireland.
Indicator nine
An orderly Flood Re exit
Flood Re continues to ensure the widespread availability and affordability of insurance: 99% of flood risk sample continue to able to get 15+ quotes from price comparison websites, and 98% of those with recent flood claims were able to get 5+ quotes. Inflation in the insurance market was significant over the last year, with premium quote inflation for buildings & contents policies surging by roughly 40% during the year, and the ABI’s figures showing the average premium price in Q1-2024 up by 19% over a year prior, to £375. Flood Re’s tracking of flood risk properties shows proportionate but very slightly lower price increases for flood risk properties.
Indicator ten
Improving consumer information on flooding and the value of insurance
There has been a considerable rise in the cost of insurance premiums this year (as noted under Indicator 9). This appears to be driving some households to cancel their home insurance – ABI figures show 3-5% fewer policies written in 2023/24 compared to the year prior. There has also been some evidence of households moving to ‘essentials’ products, meaning that householders may have thinner coverage than previously. However, ‘essentials’ products for home insurance have not been found to lack important coverage elements, and, crucially, there is no evidence of insurers seeking to unbundle cover to remove flood protection, as has been seen in other countries.
The implementation of the Consumer Duty has increased the requirements on insurers to be clear and transparent with their consumers about their insurance cover, which will also present future opportunities for engagement on PFR via BBB. Flood Re has undertaken several initiatives to raise awareness about flood risk, as noted in Indicator 6 – but most householders continue to be unaware of their levels of flood risk.
Indicator eleven
Active engagement in the market, and insurers’ engagement with flood risk issues
The number of insurers offering Build Back Better (BBB) continues to grow, with more insurers coming on-stream over the next few months as well as the first Managing General Agent – Prestige Underwriting – committing to offering BBB. There was strong insurer engagement within COP 28, especially on adaptation and resilience. The ABI have launched an investment delivery forum to invest in clean energy and infrastructure assets utilising the freedoms expected to be created by Solvency UK, with £100B commitment from insurers.
Global trends in reinsurance markets have given rise to concerns. Reinsurance costs have soared over the past two years, owing to inflation and the growing prevalence of climate-related disasters. This has led Flood Re to need to increase the levy charged to the insurance industry to £160m from £135m per annum. But were Flood Re not in existence, the tightening reinsurance market would have added pressure directly to insurers offering flood cover in the UK.
Delivering on our key commitments
Since the Transition’s Plan launch, Flood Re has made significant progress in delivering our key commitments.
Understanding the effectiveness of the planning system in upholding flood protection
New builds at flood risk were a key concern raised with Flood Re during the engagement for the Transition Plan. In England, about 9% of new buildings are built on the functional flood plain. Planning guidance stipulates these homes should be protected in various ways, but there is very little information available as to effectively this is enforced.
To understand this question, Flood Re partnered with the Town and Country Planning and Association to undertake a deep dive of planning applications in England. This work was informed by an advisory board composed on people with different perceptions on the system this included planners, developers, insurers, lenders and flood specialists.
The research included a detailed examination of the flood mitigation conditions in two local authority areas and a deep dive of the planning process for two developments in an area of flood risk. This allowed us to examine:
- How flood risk was assessed at different stages of the planning process and what information was used to inform this assessment
- What flood mitigation conditions were included in the planning process and how this varied depending on the way in which planning consent was granted
- The degree to which these mitigations were upheld throughout the process, and whether this changed depending on where in the process the mitigations were set out.
This research will be published in Summer 2024.
Leading the creation of Flood Performance Certificates
A Flood Performance Certificate (FPCs) is a simple concept: it’s a way of setting out what type of resilience to flooding a property has. In other words, it tells a householder what would happen if there was a flood. FPCs are not a new idea, but in the Transition Plan Flood Re committed to making them a reality, and in the year since we have engaged extensively with potential users to understand how they could be utilised, and what will be needed to make them a success.
The engagement identified a wide range of potential use cases for FPCs, across the public sector, insurance, lending and planning. All of these use cases rely on the same thing: information about property flood resilience to be assessed consistently so it can be communicated effectively. Moreover, it is also needs to empower the householder to understand their home, and how they can protect it.
In June 2024, Flood Re published our FPC Roadmap, a document that sets out the benefits FPCs can provide and the steps Flood Re will take to ensure these can be realised.
Engaging partners in the creation of a Homes, Floods and Insurance Hub
The Transition Plan 2023 set out Flood Re’s commitment to establish a body to act as centre for excellence in to mitigating flood risk at a property level, and specifically link this to future insurability. To inform the creation of this body, during 23/24 Flood Re undertook and comprehensive and systematic evaluation of the UK’s research capabilities in relation to flooding.
The analysis found that there were several areas where the UK had a very rich knowledge ecosystem, including in flood modelling and hydrological modelling. But the research also identified that research into flooding tended to be divided between distinct academic provisions, leaving several gaps in our knowledge and posing particular barriers to ensuring this knowledge can be acted on effectively.
The Homes, Floods and Insurance Hub that Flood Re has announced will be a partnership between Flood Re, the insurance industry and the research community that will bring about clear evidence on the most effective measures reduce flood risk at household level to help homeowners to reduce damage and insurers to reduce risk. The Hub will generate actionable information on the effectiveness of home resilience measures; provide authoritative evidence and support standards for practice.
