Millennium Insurance Company Limited · DRN-6207560

The complaint Miss J is unhappy with Millennium Insurance Company Limited’s decision to decline her income protection claim. What happened Miss J had an accident, sickness and unemployment policy with Millennium which she took out on 4 November 2024. A few months later, in March 2025, she was made redundant from her role as HR Group People Director. She claimed on her policy only to be told her claim was declined. Miss J would like her claim paid and noted other insurers had already accepted her claim. Millennium said it was unable to verify important information from Miss J and her previous employer about when she first became aware her role was at risk. It said it contacted her previous employer, only to be told it wouldn’t provide the necessary information for legal reasons. Millennium also said it had concerns about what Miss J knew and when, given her position as HR Director. It noted her previous employer had made several redundancies in the lead up to Miss J sourcing the policy. Our investigator didn’t uphold this complaint. She said it’s for Miss J to show she has a valid claim under the policy. She also said the information Millennium requested is key to determining whether the policy should pay out and so Millennium could reasonably decline her claim without it. Miss J, unhappy with that, asked for an ombudsman to review her complaint. In summary, she said she purchased the policies following the breakdown of her relationship and wanted the peace of mind that comes with the cover. She said she was unaware her role was at risk and the first she heard of that was 10 March 2025. There was no consultation period in her case because she accepted the offer made by her previous employer. She suspects that’s the reason they won’t disclose the necessary information the insurer asked for. Miss J also said she’s provided enough information to support her claim and that Millennium hasn’t shown it can fairly decline her claim for the reasons it has. And so, it’s now for me to make a final decision. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Having done so, I’ve decided not to uphold it and for broadly similar reasons given by our investigator. It’s Miss J’s responsibility to show, through evidence, she has a valid claim under the policy. Millennium has been unable to validate her claim because it’s been unable to gather the necessary information related to the exact date Miss J was made aware her role was at risk. I’m persuaded this is crucial information for the insurer to determine whether her claim is payable and therefore it can reasonably decline in the absence of this information. I’ll explain why.

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The relevant rule in this case comes from the Insurance Conduct of Business Sourcebook (ICOBS) and says Millennium must handle claims promptly and fairly and must not reject a claim unreasonably. I’ve considered this, alongside other relevant industry guidance, whilst assessing Miss J’s claim. I should also say that I’ve not addressed every point made by either Miss J or Millennium, rather, I’ve focused on what I consider to be relevant to the crux of the issues complained about in this case. So, if I’ve not mentioned something specifically, it’s not because I haven’t seen it, I’ve chosen not to refer to it as part of my final decision. The rules that govern this service enable me to do that so that I can resolve complaints with minimal formality. The policy terms say: “Claims where we have not received sufficient evidence to confirm your unemployment; for example, claims where you are unable to provide evidence that you were previously employed or where you are unable to provide evidence that you are registered as unemployed with the appropriate government agency and actively seeking work.” And: “• Must not be aware of any impending unemployment or that there is a risk you may become unemployed. If you are self-employed, you must not be aware of any reasons which would mean your business is likely to close; • Must not be aware of any redundancies, restructure, reorganisation, financial or contractual threats within the organisation you work in, even if you do not believe these actions will result in you becoming unemployed;” There’s also an initial exclusion period on this policy which excludes claims that arise during that 120-day period. The policy says under what’s not covered: "c. Claims where during the initial exclusion period: • you are notified of your unemployment even if your last day in work falls outside of this period; • you are made aware that there is a risk you could be made" Millennium highlighted the significance of the above terms and said Miss J’s initial exclusion period ended on 4 March 2025. It said because she signed a settlement agreement 10-days later on 14 March, it wanted to understand when Miss J was made aware her role was at risk of redundancy. I think that’s a reasonable position to take in the circumstances as if it were to be determined Miss J was made aware of this at least 10 days earlier, then her claim would be caught by the exclusion period. Miss J said she was made aware her role was at risk on 10 March 2025, some six days after the initial exclusion period had ended. Although it’s unclear how many employees were part of this exercise, typically, I’d have expected there to be a consultation period but Miss J said this didn’t happen. Millennium contacted Miss J’s previous employer to try to establish the date she was made aware, however, the response simply indicated she was told in March and didn’t provide a date. I’m persuaded that’s not specific enough as the exact date is a critical piece of the puzzle in this case for the reasons I’ve explained. Millennium made reasonable attempts to narrow down the exact date and explained the importance of this information to Miss J’s previous employer, only to be told it won’t be responding any further due to legal advice it’d received. It’s unclear what this advice was and why, given the insurer shared the consent it received from Miss J, its position was to withhold this evidence. But I’m persuaded without it,

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Millennium’s unable to reasonably validate Miss J’s claim. Miss J argued Millennium cannot fairly rely on the initial exclusion period to decline her claim. But that’s not what’s happened, rather, the insurer’s unable to validate her claim. In other words – Miss J hasn’t shown she has a valid claim because she’s unable to evidence it. I accept she’s provided a lot of other evidence, but that doesn’t negate the absence of this information. The insurer has reasonable concerns about what Miss J knew about the security of her role and when, given she held a senior HR position. It noted the employer reported wider redundancies in the run up to Miss J sourcing the policy in 2024 and after she took the policy which fell within the initial exclusion period. And so, I’m persuaded the information Millennium asked for is significant to the validation of Miss J’s claim and because it’s unable to verify it with her previous employer, it can reasonably decline liability for Miss J’s claim. Millennium said should Miss J try to speak with her previous employer to resolve its concerns about any legal ramifications around sharing the information. The insurer said it will reconsider her claim, once the requested information has been provided. I thought that was a fair position to take in the circumstances. Miss J made other arguments about other insurer’s accepting her claims based on the same information provided to Millennium. But that doesn’t automatically mean Millennium should accept her claim. The individual policy terms are the starting point for any claim and in this case, the insurer has been unable to determine crucial information around the circumstances of Miss J’s redundancy. My final decision For the reasons I’ve explained, I don’t uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Miss J to accept or reject my decision before 18 April 2026. Scott Slade Ombudsman

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