Financial Services Council (FSC) on behalf of its Member Life Insurance Companies


On 6 April 2020, the Financial Services Council, on behalf of its member life insurance companies, lodged an application for authorisation to give effect to a commitment to ensure that frontline healthcare workers are not denied life insurance, will not be charged higher premiums and will not have benefits excluded, purely due to exposure, or potential exposure, to COVID‑19 (the Proposed Conduct).

The Financial Services Council also requested interim authorisation for the Proposed Conduct on an urgent basis so that insurers could start implementing the commitment as soon as possible.

On 9 April 2020, the ACCC granted urgent interim authorisation to the Proposed Conduct.

The ACCC is conducting a public consultation process on our decision regarding interim authorisation and the substantive application for authorisation. Details regarding how to make a submission are available in the correspondence below.

If you intend to provide a submission please do so by Friday, 15 May 2020. Submissions should be emailed to with the subject ‘Financial Services Council - AA1000494 - Submission’. In addition, should you wish to make a submission beyond 15 May 2020 in relation to your experience with the impact of the conduct, please contact the ACCC at

We recognise that the COVID-19 situation may be causing disruptions to your normal operations. For this reason we are taking a flexible approach to receiving feedback on the conduct. You may wish to contact us by phone to discuss your views or submission before the deadline.

Further information on the application for authorisation and the ACCC’s interim decision is available through the links below.

An indicative timetable is below. This timetable is subject to change.


6 April 2020

Application for authorisation (and interim authorisation) lodged.

9 April 2020

Interim authorisation granted.

23 April 2020

Public consultation process begins.

15 May 2020

Closing date for submissions on the substantive application for authorisation from interested parties.

June 2020

Applicant responds to issues raised in the public consultation process.

July 2020

Draft determination

July 2020

Public consultation on draft determination including any conference if called.

September 2020

Final determination.



  • Financial Services Council

Authorisation number(s)

  • AA1000494-1