Pubs and premises insurance

In March 2025, the Pubs Code Adjudicator (PCA) wrote to all pub-owning businesses to reinforce the importance of complying with Regulation 46 of the Pubs Code. This regulation focuses on how premises insurance is handled and, crucially, the tied tenant’s right to seek a price match on insurance premiums.

Under Regulation 46, pub companies must give tenants full information about the premises insurance arrangements when the tenant is expected to pay the cost. This includes explaining how premiums are calculated and giving tenants the chance to shop around for a policy that offers similar cover at a lower price. If a tenant finds such a policy and it meets the standard of being “suitable and comparable,” the pub company must either take out that policy or agree in writing not to charge the tenant the difference.

The PCA’s action follows a compliance review in 2024 involving Star Pubs & Bars, which led to improvements in how Star explains insurance charges to tenants. Building on that, the PCA contacted all pub companies in October 2024 to encourage similar improvements, especially where self-insurance schemes are in place.

More recently, the PCA expressed concern that many pub companies may not be properly honouring the price match right. A key issue is clarity. Some companies appear to reject tenant-proposed policies on the basis that they aren’t “equivalent” or “better” than the company’s own. The PCA has reminded businesses that this isn’t the correct test. The law only requires a policy to be “suitable and comparable,” not identical.

Worryingly, the PCA’s 2024 Annual Tied Tenant Survey revealed that just 56% of tenants knew they had the right to challenge insurance costs through price matching. This lack of awareness could mean many tenants are paying more than they need to.

In its latest communication, the PCA has urged all pub companies to double-check their compliance with Regulation 46 and ensure that communications with tenants clearly explain the price match right. Businesses should avoid technical or vague language and give tenants confidence to use their rights without hassle or delay.

The PCA is also encouraging tied tenants and other stakeholders to share their experiences. Feedback helps the regulator assess whether the rules are being followed fairly and consistently across the industry.

By promoting awareness and pushing for fair treatment, the PCA is aiming to create a more transparent and balanced environment for tied pubs across England and Wales.