Intentional News

2026-10-02 Comparison sites and the price you are shown

6 min read

Is your quote being gamed? Comparison sites and the price you are shown

Why this note exists. the owner, 2 Oct 2026, on the Many Happy Returns episode: “can you evaluate the thesis raised in this podcast that comparison sites already deploy gaming techniques to deliver different prices at different times. I have not experienced that when I’m shopping for insurance I think but wonder if it may be true.” Filed here because the answer is a household-shopping question, not a portfolio one.

Thesis (Alf’s read): the pricing behaviour is real, but the podcast aims at the wrong target. Quotes genuinely move over time — that is permitted on purpose by UK regulation. The genuine distortions are the commercial ranking of comparison sites and the intro-price machine, not your laptop’s operating system.

What was claimed, and what is actually true

The claim has three separate mechanisms folded into it. Only some survive checking.

1. “Different prices at different times” — TRUE, and deliberately allowed

The FCA’s General Insurance Pricing Practices rules (PS21/5, in force 1 January 2022) explicitly permit:

  • new-business price optimisation — varying prices to win customers;
  • using machine-learning and algorithmic models in the pricing chain;
  • demand-elasticity models applied to new-business pricing.

What they prohibit is charging a renewing customer more than the Equivalent New Business Price (ENBP) for the same risk through the same channel, plus systematic price walking and cancellation sludge. So an insurer can lawfully show a different price tomorrow, or to a different person, based on demand modelling. Your quote moving is not a trick — it is the business model the rules leave open.

2. “The loyalty penalty” — TRUE, and it was the real scandal

This is almost certainly the “gaming” the podcast gestures at. For years, home and motor insurers offered a cheap first-year price and then walked it up at every renewal, on the assumption — correct on average — that customers do not shop around. The FCA’s market study found long-standing customers were systematically charged more than equivalent new customers. Banned for home and motor from 1 January 2022. The FCA’s own three-year evaluation (EP25/2, July 2025) found price walking largely eliminated.

This is why the owner’s experience is consistent: the specific gaming he expected to feel was real, was documented, and has been illegal for nearly four years. Not feeling it now is the regulation working.

3. “Comparison sites game it” — TRUE, but as commercial ranking, not fake prices

Comparison sites are paid by the insurer — market estimates put motor commission around £20–£40 per completed policy. ICOBS requires paid placement to be labelled (“sponsored”, “promoted”, “featured”), so the order you see is not purely cheapest-first and the site is not a neutral referee. The CMA’s online-choice-architecture work is blunt about it: ranking exerts a strong effect on consumer behaviour — it is one of the most powerful levers a site holds, and it is commercially set.

What is not evidenced is the site inventing prices. It is a paid shop window, not a rigged one.

4. “Different price by device, IP or time of day” — TRUE elsewhere, NOT established for UK insurance

Device- and location-linked pricing is documented in travel and retail: academic work found hotel prices averaging 2–11% higher for searches from Apple devices than Windows; the FTC’s 2025 surveillance-pricing study confirmed device attributes are used to individualise prices in retail and travel. In UK insurance the differentiation that exists is by risk factors and channel, not by handset — which is exactly why the owner, shopping for insurance, has never noticed a device effect. He would be more likely to see it booking a hotel.

What this means for how we shop

  • Do not re-quote the same policy repeatedly and expect the same number — new-business pricing is optimised continuously. Take a comparison once, properly, and act on it.
  • Compare on identical cover and excess. Insurers may price legitimately by channel, so a direct quote and a comparison-site quote for “the same” policy are not the same product.
  • Read the ranking sceptically. Use the sponsored/featured labels, and sort by the column you care about rather than accepting default order. The top result is a commercial position as well as a price.
  • At renewal, test the ENBP rule. Your renewal must not exceed the equivalent new-business price for the same risk through the same channel. If it does, that is a regulatory breach worth a complaint, not a negotiation.

[! Important]

  • The one honest use for AI agents here (the episode’s own subject): re-quoting, checking the sponsored labels, and testing the renewal price against the new-business price is exactly the tedious comparison a persistent agent should do — and it is the version of “gaming the gamer” that is legitimate, because it is your side of the same information asymmetry.

What remains unverified

  • The £20–£40 motor commission figure is a market estimate from a trade source, not an FCA or CMA statistic — treat it as indicative.
  • The device-pricing studies are travel/retail, mostly US. I found no UK insurance evidence either way, so “not established” is not the same as “does not happen”.
  • The FCA evaluation (EP25/2) is reported here from secondary summaries, not read in full.

Sources

  • FCA PS21/5 (General Insurance Pricing Practices, May 2021; core rule in force 1 Jan 2022) — the ENBP rule, price-walking ban; and its permitted new-business price optimisation. Read: secondary summaries, 2 Oct 2026.
  • FCA EP25/2 (July 2025) — three-year evaluation, price walking largely eliminated. Reported 2 Oct 2026.
  • CMA Online Choice Architecture discussion paper + evidence review (5 April 2022) — ranking as a strong influence on consumer choice; personalisation as a recognised practice.
  • ICOBs disclosure requirement for sponsored/promoted placement on comparison sites. Reported 2 Oct 2026.
  • Device-based pricing: hotel pricing 2–11% Apple vs Windows (Journal of Marketing Research, reported); FTC surveillance-pricing study (January 2025). Both travel/retail, not UK insurance.
  • Commission range £20–£40 per motor policy: trade-source market estimate, 2026 — indicative only.

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