Matilda Seccombe and Harry Purcell

PO Box 18,896 
Sutton Coldfield B73 9BL  
www.brake.org.uk  
www.globalfleetchampions.org 

Chief executive: 

Trustees: 

Linda Karen Hadfield Lee 
The Coroner’s Office Coventry and Warwickshire 
Manor House Drive 
Coventry  
CV1 2ND 

18 February 2026 

Dear Ms Lee, 

Re: Regulation 28 Report to Prevent Future Deaths 

I am writing in response to the Regulation 28 Prevention of Future Deaths report issued on 8 
December 2025 concerning the tragic deaths of Matilda (Tilly) Grace Seccombe and Harry Joseph 
Purcell. 

On behalf of Brake, I extend our deepest condolences to the families, friends, and communities 
affected by the deaths of Tilly and Harry. We recognise the profound trauma and grief caused by this 
tragedy, and we offer our sincere sympathy to everyone impacted. 

We also wish to commend you for your thorough investigation and for issuing a Prevention of Future 
Deaths (PFD) report. Such reports play a vital role in identifying risks and prompting action to reduce 
the likelihood of further loss of life. 

Your report highlights the significance of peer influence, vehicle loading, and rural road hazards for 
young drivers, and identifies uncertainty around how well these risks are understood by young 
people, parents (particularly those arranging insurance cover), and schools. These are important 
issues that require continued consideration at national level. 

Brake is a national road-safety charity. We campaign for evidence-based policies that prevent road 
deaths and injuries, raise awareness of key risks, and provide specialist support for people bereaved 
and seriously injured in road crashes. 

We have long campaigned for stronger licensing measures to protect young and newly qualified 
drivers, and this remains one of our organisational priorities. We partner with the Protect Young 
Drivers campaign, and we will shortly be releasing research undertaken last year on this issue. I will 
ensure a copy is shared with you once published. 

Education and awareness-raising are also central to our work. Brake has delivered road-safety 
education for many years, including initiatives in primary schools, and we coordinate Road Safety 
Week each November. We note the new National Road Safety Strategy’s emphasis on a lifelong 
learning approach and the government's commitment to publishing national guidance and a 
supporting manual for road-safety education. We welcome this focus and will follow its development 
closely. 

Brake is a company limited by guarantee  
with charitable objectives 
Registered in the UK No. 3260243 
Registered Charity No. 1093244 

 
 
 
 
 
 
 
 
 
 
 
 
 PO Box 18,896 
Sutton Coldfield B73 9BL  
www.brake.org.uk  
www.globalfleetchampions.org 

Chief executive: 

Trustees: 

Alongside our campaigning and education work, we operate the National Road 
Victim Service, providing specialist emotional and practical support to families 
bereaved and seriously injured in road crashes. In 2025, we supported more than 
2,000 families. The trauma we witness every day reinforces the urgency of 
effective prevention measures. 

Brake will continue to use our voice and our platforms to raise important issues 
such as those identified in your report. We do so on behalf of all families 
devastated by road crashes, with a commitment to doing all we can to prevent 
future tragedies and reduce harm where crashes still occur. 

Yours sincerely, 

Chief Executive Officer 
Brake, the road-safety charity 

Brake is a company limited by guarantee  
with charitable objectives 
Registered in the UK No. 3260243 
Registered Charity No. 1093244

Response to the Coroner’s Office of Coventry and 
Warwickshire’s Regulation 28 Report to Prevent 
Future Deaths  

Harry Joseph Purcell, Deceased and 

Matilda (Tilly) Grace Seccombe, Deceased 

Chartered Insurance Institute Response 

 
 
 
 
 
 
 Chartered Insurance Institute Response to The Coroner’s Office of 
Coventry and Warwickshire’s Regulation 28 Report  

1. Key Points  

We would like to express our sadness over the deaths of Harry Purcell and Tilly 
Seccombe, and we would like to thank the Coroner for inviting us to help develop a 
practical approach to improving road safety.  

We have also noted the article published by the BBC in which Harry’s mother, 

, called for the more effective adoption of telematics for young drivers.1 As a 

profession, we are determined to find ways to avoid tragedies such as this from 
happening in future.  

The issues the Coroner has asked us to consider are: 

• 

Industry practice does not appear to include a consistent method for identifying 
when a named driver arrangement may conceal higher-than-expected use by a 
young driver, with implications for risk assessment and safety.  

•  There is also no uniform approach to how telematics is applied or the need for its 
use communicated to young drivers. The inquest noted uncertainty about how 
clearly insurers and brokers explain the safety-related aspects of telematics to 
young drivers or their families, which may influence decisions made when 
arranging insurance.” 

• 

In response to these findings, the CII (Chartered Insurance Institute) commits to: 

•  Write to all general insurance firms that have been awarded Corporate 

Chartered status by the CII,2 to highlight the publication of the Regulation 
28 report and the issues that it raises.   

•  Work with insurers, trade associations, road safety groups, driver training 
bodies, consumer groups and the FCA (Financial Conduct Authority) to 
stimulate: 

o  higher prioritisation of young drivers as potentially vulnerable 

customers, 

1 BBC (2025), Show off driver who killed three teens sentenced at: 
https://www.bbc.co.uk/news/articles/clywee36nx5o  
2 See https://www.cii.co.uk/membership/join-us/chartered/ for more information about Chartered status, including 
Corporate Chartered status.  

 
 
 
 
 
 
 
 
 o  greater consistency in the way insurers apply good practice when 
identifying ‘fronting’ (the misuse of named driver arrangements), 
o  greater consistency in the way insurers apply good practice in the 

promotion of telematics to young drivers, and 

o  greater consistency in the way insurers apply good practice to the 

use of telematics data. 

•  The guidance will identify: 

o  the most effective methods for influencing behavioural change in 

younger drivers, and 

o  the most effective operational processes for proactive risk 

management, including the way in which data can be collected, 
interpreted and acted upon.  

•  The CII commits to completing a consultation period of four months, to June 

2026, and publishing guidance by the end of 2026.  

 
 
 
 
 2. Background to our response 

2.1 Telematics and their impact on road safety 

Adoption of telematics rose to an estimated 1.66 million policies in 2022. Over a similar 
period, between 2004 and 2024, casualties fell almost 40% faster among younger 
drivers compared to older drivers: 

•  KSI (killed or seriously injured) casualties from a collision involving at least one 
younger car driver (aged between 17 and 24) decreased from 12,190 to 4,740, a 
fall of 61% 

•  KSI casualties in collisions involving other aged car drivers decreased from 

30,967 to 19,368, a fall of 37%3 

2.2 Market incentives for telematics 

Insurers have used pricing to incentivise younger drivers to adopt telematics. 

According to the research firm, Consumer Intelligence, among drivers between the ages 
of 17-19, ‘83% find telematics cheaper, with median savings of £2,172 (116% 
difference)’ 

From ages 25-29, those considering telematics drops to 51%, as no-claims discounts 
reduce the cost of traditional insurance, and from age 35, those considering telematics 
falls below 25%.4  

2.3 Option to introduce a self-regulatory approach to adopting telematics 

A purely self-regulatory approach to forcing more drivers to adopt telematics is unlikely 
to work. 

3 Department for Transport (2025) Reported road casualties in Great Britain: younger driver factsheet at: Reported 
road casualties in Great Britain: younger driver factsheet, 2024 - GOV.UK 
4 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at: 
https://www.consumerintelligence.com/articles/insurance-industry-creating-telematics-refugees-as-2000-pricing-
penalty-forces-young-drivers-into-surveillance 

 
 
 
 
 
 
 
 
 There are two reasons for this: 

•  First, a market agreement (for example, an agreement between insurers to only 
offer insurance with telematics to drivers under a certain age) could easily be 
undermined by some insurance firms opting out of the agreement and appealing 
to customers who want traditional insurance. These firms would benefit from the 
significant proportion of drivers who dislike the reduction in privacy that comes 
with telematics (for example, a recent survey by telematics provider IMS showed 
that 62% of UK motorists were worried about sharing their personal location 
information).5 

•  Second, the greatest benefits of telematics can only be derived from a range of 
measures. For example, the research agency, Consumer Intelligence, has 
summarised some of these approaches as: 

o 

o 

o 

o 

‘Reframe Year One: Position telematics as a "Recognised Driver Journey" 
– a fast-track to trusted status, not probation 

‘Change the Language: Replace "we monitor" with "you demonstrate" 

‘Provide Real Control: Let customers choose what aspects of driving 
they want to showcase 

‘Create Lasting Value: Offer permanent recognition status that follows 
them even if they switch insurers’ 

Consumer Intelligence concluded, ‘Insurers need to stop selling surveillance 
and start selling recognition. Our research shows customers who feel recognised 
and in control have three times higher voluntary adoption rates.’ 6 

As a result, prescriptive approaches based on mandating the kind of technology used or 
the kind of communication given to drivers are unlikely to be the best route to securing 
safer driving.  

5 IMS (2026) Personalised pricing uptake to flatline in 2026 unless UK-based insurers address privacy concerns at 
https://ims.tech/news/connected-insurance-personalised-pricing-uptake-to-flatline-in-2026-unless-uk-based-
insurers-address-privacy-concerns/ 
6 Consumer Intelligence (2025) Insurance industry creating ‘telematics refugees’ at: 
https://www.consumerintelligence.com/articles/insurance-industry-creating-telematics-refugees-as-2000-pricing-
penalty-forces-young-drivers-into-surveillance 

 
 
 
 
 2.4 Option to treat younger drivers as vulnerable customers 

Although mandating technology or communications in a self-regulating environment 
may not be the best option to promote safer driving, the FCA approach to vulnerability 
may provide a better mechanism to secure more uniform adoption of good practice. 

The FCA’s approach to vulnerability requires financial services firms to adopt 
reasonable adjustments for groups of consumers who may be at greater risk of harm as 
a result of ‘drivers of vulnerability’. These ‘drivers’ are: 

•  Low financial capacity 
•  Low financial resilience 
•  Life events 
• 

Illness and disability 

The approach requires insurers to address the risks of vulnerability through a process of 
monitoring consumer behaviour, analysing and learning from the resulting data, and 
adjusting the firm’s proposition to improve outcomes.7  

There is a strong argument that young drivers and their families are more vulnerable 
than other motor insurance customers, because: 

•  Being a new driver is a life event that carries risks – since new drivers are less 

aware of the risks of driving, and their families are likely to be less aware of the 
risks of committing fraud through ‘fronting’. 

•  New drivers have lower levels of financial capability than other motor customers, 
because they are less likely to have experience of repeat purchases of motor 
insurance. 

•  New drivers often have lower levels of financial resilience, which may increase 

safety risks (for example, if they are not able to afford vehicles with non-
compulsory safety features).  

There is also a strong argument that insurers should develop an approach to younger 
drivers that will help them to overcome these risks, for example through: 

•  Better consumer understanding of the risks involved with being a new driver. 
•  Better consumer understanding of the benefits of telematics.  

7 Financial Conduct Authority (2021) FG21/1 Guidance for firms on the fair treatment of vulnerable 
customers at FG21/1: Guidance for firms on the fair treatment of vulnerable customers and Financial 
Conduct Authority (2022)  FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty 
FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty at FG22/5: Final non-Handbook 
Guidance for firms on the Consumer Duty 

 
 
 •  Better product governance, including being more willing to refuse insurance to 

younger drivers who pose a significant risk.8  

2.5 CII Commitments  

The CII commits to encouraging the insurance community to consider younger drivers 
as potentially vulnerable consumers through: 

•  Developing guidance for the profession on the aspects of new drivers that makes 
them more vulnerable. The CII has recently published guidance for members on 
vulnerability (Managing customer vulnerability in insurance and personal 
finance: A practical implementation guide) that explores how vulnerability can be 
put into practice through the effective use of leadership, systems, data 
management and training, with a particular emphasis on effective data 
management. We will build on these insights when producing the guidance.9 

•  Working with insurers, trade associations, road safety groups, driver training 
bodies, consumer groups and the Financial Conduct Authority to build on 
existing good practice (such as the BIBA Good practice guide to selling 
telematics10) to stimulate: 

o  higher prioritisation of young drivers as potentially vulnerable customers 
o  greater consistency in the way insurers apply good practice when 

identifying the misuse of named driver arrangements 

o  greater consistency in the way insurers apply good practice in the 

promotion of telematics to young drivers,  

o  greater consistency in the way insurers apply good practice in the use of 

telematics data to improve road safety. 

In doing so, we will focus on factors identified by telematics providers are areas for 
improvement, including: 

•  Methods for influencing behavioural change in customers   
•  Operational processes for proactive risk management, including the way in 

which data can be collected, interpreted and acted upon.11  

The CII commits to completing a consultation period of four months, to June 2026, and 
publishing guidance by the end of 2026.   

8 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/ 
9 Chartered Insurance Institute (2025) Managing customer vulnerability in insurance and personal 
finance: A practical implementation guide at Managing customer vulnerability in insurance and personal 
finance: A practical implementation guide 
10 BIBA (2022) Good practice guide to selling telematics at: https://www.biba.org.uk/technical-updates/good-
practice-guide-to-selling-telematics/ 

11 IMS (2023) Telematics Rules OK? at https://ims.tech/knowledge-hub/telematics-rules-ok/

From the Parliamentary  
Under Secretary of State 

Great Minster House 
33 Horseferry Road 
London 
SW1P 4DR 

        17 February 2026 

Linda Karen Hadfield Lee 
Acting Area Coroner for Coventry and 
Warwickshire 
Coroner’s Office 
Warwickshire Justice Centre  
Newbold Terrace 
Leamington Spa 
CV32 4EL 

Dear Linda Karen Hadfield Lee, 

RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE 
DEATHS 

Thank you for your letter of 18 December 2025, enclosing your Regulation 28 
Report to Prevent Future Deaths dated 8 December 2025 made under the 
Coroners and Justice Act 2009 and the Coroners (Investigations) Regulations 
2013, following the inquest you conducted into the deaths of Harry Jospeh 
Purcell and Matilda ‘Tilly’ Grace Seccombe. 

I am deeply saddened by the circumstances of the deaths of Harry Purcell, 
Tilly Seccombe, and Frank Wormald, and I would like to extend my sincere 
condolences to their families.  

I am responding on behalf of two of the addressees of your report, the 
Department for Transport and its executive agency the Driver and Vehicle 
Standards Agency (“DVSA”). 

Improving road safety is one of my Department’s highest priorities. Too many 
people are killed and seriously injured in road traffic collisions, and this 
Government will work hard to prevent these tragedies for all road users.  

The latest statistics do show that the number of car fatalities involving 17 to 
24-year-olds on Britain’s roads is falling – from 448 in 1990 to 73 in 2024. 
This is an 84% total decrease. However, this Government acknowledges that 
there is still work to be done. In terms of population and the number of miles 
driven, 17– 24-year-olds, particularly young men, remain one of the highest 
fatality risk groups both as car drivers and passengers.  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 That is one reason why, on 7 January 2026 my Department published a new 
Road Safety Strategy, setting out the Government’s vision for a safer future 
on our roads for all. The Strategy sets an ambitious target to reduce the 
number of people killed or seriously injured on British roads by 65% by 2035. 
This target will focus the efforts of road safety partners across Britain, with 
measures to improve road design, protect vulnerable road users, and review 
motoring offences. All of this will be supported and monitored by a new Road 
Safety Board which I will chair.    

 Whilst we are not considering further restrictions on newly qualified drivers 
such as carrying passengers or driving at night, we are consulting on a 
Minimum Learning Period in England, Scotland, and Wales before learner 
drivers can take their practical driving test.  

As part of our consultation into a Minimum Learning Period, we are asking 
about including a mandatory modular syllabus as part of the new mandatory 
learner requirements. Learner drivers are already encouraged to gain 
experience in a range of driving conditions as part of their learning journey. 
This includes practice during nighttime, on rural and urban roads, in poor 
weather and on higher-speed roads. Exposure to varied scenarios helps 
learners develop competence, adaptability and preparedness for real-world 
driving. A modular learning syllabus could formalise this approach by 
requiring structured experience across diverse conditions. 

We know from research carried out in other countries that introducing a 
“Minimum Learning Period” has potential to reduce the number of deaths and 
serious injuries. 

 This is why we are consulting on the introduction of pre-test measures and 
combining these with the post-test measures already in place through the 
Road Traffic (New Drivers) Act 1995. That Act has a form of “probationary 
period” of 2 years for novice drivers of all ages in Great Britain. During this 
time, instead of the standard 12 points, if 6 or more points are received, 
including in the learning period, a driver's licence is revoked and they must 
apply again for a provisional licence, re-entering the learning stage.       

Additionally, as part of the motoring offences consultation, we are consulting 
on a lower blood alcohol limit for novice drivers in England and Wales.     

Turning to the concerns raised regarding the scope of the current driving test: 
the object of the driving test is to ensure that the candidate is well grounded 
in the basic principles of safe driving and is sufficiently practised in them to be 
able to show, at the time of the test, that they are a competent and 
considerate driver and are not a source of danger to themselves or to other 
road users. If a candidate reaches the required standard they will pass their 
test. However, it is not intended to, and could not, replicate every scenario a 
driver may encounter after qualification. 

 
 
 
 
   
 The driving test has been continually reviewed and has undergone many 
changes over the years, which includes adding the sat nav for the 
independent driving. This is to ensure that it is fit for purpose for today’s roads 
and meets current legislative and road safety requirements.  The test remains 
under constant review.   

Following a successful five-month trial, the DVSA introduced updates to the 
car practical driving test from Monday 24 November 2025. As a result of 
these changes, learner drivers will spend more time on higher-speed roads 
during their driving test, where location allows. These changes aim to 
enhance road safety, address collision rates in rural areas and align the test 
more closely with real-world driving conditions. 

Reviewing and refreshing all current routes will take time. The expectation is 
that by 31 March 2026, each Driving Test Centre will have reviewed and 
updated all routes to be more relevant and to include high speed, high risk 
rural roads where location allows.  

Vehicle loading and passenger dynamics are important aspects of safe 
driving, but these situations vary significantly depending on vehicle type and 
usage. For this reason, the test focuses on core competencies such as 
hazard perception, vehicle control, and decision-making, which are 
fundamental to adapting safely to different conditions. Learner drivers have 
the option to carry passengers during their learning journeys.  

The theory test includes questions on vehicle handling and loading to help 
learner drivers understand the key road safety considerations involved.  

DVSA promotes ‘Pass Plus’, which is a practical training course that takes at 
least 6 hours and is for drivers to improve their skills and drive more safely. It 
can be taken at any time although it should be most useful to new drivers in 
the year after passing their test. 

Pass Plus training takes at least 6 hours. It has 6 modules, covering driving: 

in town 
• 
in all weathers 
• 
•  on rural roads 
•  at night 
•  on dual carriageways 
•  on motorways 

https://www.gov.uk/pass-plus 

Some motor insurance companies offer discounts for drivers who complete 
the ‘Pass Plus’ scheme. 

DVSA produces a number of guidance documents to assist drivers, including 
the ‘Highway Code’, ‘The Official DVSA Guides to Driving – the essential 
skills’ and ‘The Official DVSA Guide to Riding – the essential skills’.  Further 
information on these guidance documents can be viewed via the following 
links -    

 www.gov.uk/guidance/the-highway-code   

 
 The Official DVSA Guide to Driving - the essential skills   

The Official DVSA Guide to Riding - the essential skills   

DVSA advises learner drivers and Approved Driving Instructors (ADIs) to 
ensure that candidates for a driving test are sufficiently prepared and ready to 
drive independently and sit a driving test.  

The Ready to Pass campaign was launched in July 2022. The campaign 
targets learners, their parents, and driving instructors in Great Britain. It aims 
to improve learners’ understanding of what it means to be test ready and how 
they can assess their readiness. The campaign also advises to delay a test if 
an individual is not ready. 

https://readytopass.campaign.gov.uk/ 

DVSA encourages the ADI industry to take lessons in different weather 
conditions and on rural and urban roads as well as motorways. In addition, 
the DVSA encourages ADIs to provide learner drivers with a mock driving 
test, that takes place on a variety of roads, including rural roads with higher 
speed limits and dual carriageways with the national speed limit.   

https://www.gov.uk/guidance/carry-out-mock-driving-tests-for-your-pupils 

I want to reiterate that this Government treats road safety seriously, and we 
are committed to reducing the numbers of those killed and injured on our 
roads.  

The consultation on introducing a Minimum Learning Period for learner 
drivers closes on 11 May and can be found at the following link:  
https://www.gov.uk/government/consultations/introducing-a-minimum-
learning-period-for-learner-drivers/introducing-a-minimum-learning-period-for-
learner-drivers-category-b-driving-licence   

Once this and other road safety consultations have concluded, we will publish 
our responses in due course. 

Best wishes, 

MINISTER FOR LOCAL TRANSPORT

Linda Karen Hadfield Lee
Acting Area Coroner for Coventry and Warwickshire
The Coroner’s Office Coventry and Warwickshire

9 January 2026

Dear Linda Karen Hadfield Lee,

Thank you for your email of 18 December 2025 containing your report 
highlighting your concerns following the two tragic deaths of teenagers in a 
road traffic collision. We offer our condolences to the affected families. We 
recognise the seriousness of the circumstances leading to these tragic deaths 
and provide our considered response below.

FCA’s role

The Financial Conduct Authority (FCA) regulates financial businesses – 
including insurers and insurance intermediaries, under powers granted by the 
Financial Services and Markets Act 2000. 

Our role is to ensure that markets function well, including protecting 
consumers and promoting effective competition in the interests of consumers. 
We set and enforce standards in insurance for product governance, pricing 
practices, and transparency, so that insurance products provide fair value and 
firms deliver good outcomes for customers in line with their Consumer Duty 
obligations (the Duty).

As we are not the competent authority for matters concerning driver or road 
safety, we cannot direct insurers in these areas, such as requiring specific 
product features or mandating the use of telematics. Those decisions sit with 
the Government through primary legislation.

  
 
 Motor insurance and the role of telematics

Motor insurance provides financial protection for motorists against loss or 
damage, and to indemnify other road users or members of the public for loss 
or damage for which they are liable. The core purpose of insurance is to 
manage financial risk, not to prevent accidents.

Telematics motor insurance policies – sometimes referred to as “black box” 
insurance – use technology to monitor driving behaviour and usage patterns. 
This enables insurers to offer premiums to policyholders based on actual risk 
rather than using demographic averages. There can be important wider 
benefits from telematics where it leads to more careful driving and fewer 
accidents, including those resulting in death or injury.

Recent data from Mintel shows that telematics-based policies account for 
around 14% of all UK motor insurance policies. In addition, the Government’s 
analysis within the Motor Insurance Taskforce Report published in December 
2025, highlights that although drivers may be aware of the benefits of 
telematics policies, uptake remains low. 

It is also possible to include named drivers in telematics policies and the 
named driver’s driving behaviour is likely to impact the premiums of the main 
policyholder. We expect insurers to ensure any key product features and 
limitations are clearly explained so that customers understand these, including 
how their driving data from telematics could impact their premiums. 

Mandating telematics for all new young drivers (including new young named 
drivers) could have a material effect on pricing of motor insurance, potentially 
restricting consumer choice. It could, for example, disadvantage those without 
compatible technology or those financially constrained, making insurance 
unaffordable for some, and potentially increasing uninsured driving. Any 
consideration of the desirability or otherwise of making telematics mandatory 
for the purposes of reducing accidents and/or improving driving standards falls 
outside our remit. 

Fronting

We also take the opportunity to comment on the practice of ‘fronting’ 
mentioned in your report, albeit noting that it did not apply in this case. 
‘Fronting’ is the practice of naming a person as main driver for the purpose of 
obtaining a lower premium, on behalf of a different person (usually a young 
driver). A person knowingly obtaining insurance on this basis is committing a 
fraud which, if discovered, can lead to serious penalties. The Insurance Fraud 
Bureau, an industry-funded body, works with the police and insurance industry 
to combat this and other fraudulent practices. 

 Next steps

We have carefully considered the matters raised in your report. While we 
cannot act beyond our statutory remit, we remain committed to ensuring that 
firms meet the highest standards under our existing rules. We continue to 
encourage effective and appropriate use of telematics data in the insurance 
sector.

Yours sincerely,

Director, Competition and Interim Director, Insurance

The ABI’s Response to The Coroner’s Office, 
Coventry and Warwickshire: Regulation 28 
Report to Prevent Future Deaths 

05.02.2026 

 
 
 
 
 
   About us 

The ABI is the definitive voice of the UK’s world-leading insurance and long-term savings industry, 
which is the largest sector in Europe and the third largest in the world. We are not a regulator, nor do 
we have powers to compel insurers to conduct their operations in specific ways. 

We represent more than 300 firms within our membership including most household names and 
specialist providers, providing peace of mind to customers across the UK.  

Our sector is productive, inclusive and essential to the UK economy and together, we are driving 
change to protect and build a thriving society. 

Find out more at abi.org.uk 

The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026 

 
 
 
 
 
 
 
 
 
 The ABI’s Response to The Coroner’s Office, Coventry 
and Warwickshire: Regulation 28 Report to Prevent 
Future Deaths 

The ABI would like to express our deepest condolences to the families and friends of Harry Purcell, 
Matilda Seccombe, and all those affected by the tragic events of 21 April 2023.  

We have carefully considered the Coroner’s detailed Report of 8 December 2025 and, in preparing this 
response, hope that we have addressed the concerns raised regarding the role of the insurance sector in 
helping to prevent future deaths. 

We note the specific issues identified in section D of the Report, concerning industry practices around 
named driver arrangements, telematics adoption, and the communication of safety-related aspects of 
telematics to young drivers and their families. We also wanted to share information on how the wider 
motor insurance industry supports young drivers and improved road safety measures. 

Industry support for young drivers and road safety  

The primary purpose of motor insurance is to provide financial protection to vehicle owners for damage 
caused to their own vehicle, or damage or injury they cause to others. A minimum of third-party motor 
insurance is a legal requirement to drive on UK roads.  The ABI is actively engaging with its insurer 
members through our Motor Insurance Roadmap to support young drivers, and we continue to advocate 
for progressive policy change at the government level. We strongly welcome the Government’s recent 
Road Safety Strategy and endorse several key measures designed to protect young and novice drivers, as 
well as the wider public. The motor insurance industry also invests in and advocates for improved road 
safety to prevent accidents from occurring. This includes: 

•  Graduated Driving Licences / Progressive Driving Licence: The industry supports the 

introduction of phased driving licences, where new drivers gradually gain experience under lower-
risk conditions. This system may include restrictions such as limits on carrying passengers, 
reduced alcohol limits, or engine size restrictions for a set period. The aim is to reduce risks for 
newly qualified drivers and encourage safer habits as they build experience. 

•  Telematics-based Insurance: Insurers offer telematics (or ‘black box’) policies that use 

technology to monitor driving behaviour, such as speed, braking, cornering, and the times of day 
the vehicle is used. Good driving is rewarded with lower premiums, while risky behaviour may 
result in higher costs, thereby incentivising safer driving, especially among young drivers. 
•  Road Safety Education and Campaigns: The industry invests in public awareness campaigns 

and educational initiatives—often in partnership with road safety charities—to inform drivers 
about the dangers of speeding, drink-driving, mobile phone use, and other risky behaviours. 
•  Collaboration with Government and Stakeholders: Insurers work closely with government 

bodies, police, and road safety organisations to advocate for policy changes and support national 
strategies aimed at reducing road accidents, such as supporting minimum learning periods and 
improved driving tests. 

•  Data Analysis and Research: By analysing accident data, claims trends, and emerging risks, the 

industry helps identify problem areas and inform both policy and product development, 
contributing to evidence-based improvements in road safety. 

The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026 

 
 
 
 
 
 
 •  Product and Vehicle Innovation: Development of insurance products that reward safe driving 

behaviour, such as no-claims discounts and incentives for installing advanced safety features or 
using telematics, further encourages safer driving. Additionally, insurers fund and support the 
work of Thatcham Research, the UK’s automotive research centre, to enhance vehicle safety 
standards. Thatcham Research leads in testing and promoting advanced safety technologies and 
crash prevention measures, helping to make vehicles safer for all road users.   

Industry Practice: Named Driver Arrangements 

The ABI recognises the critical importance of accurately assessing risk, particularly in relation to young 
and newly qualified drivers, who unfortunately statistically face a higher likelihood of being involved in 
road traffic incidents. The buyer of the motor insurance policy should correctly declare the main user of 
the insured vehicle, as this helps insurers determine the level of risk associated with each policyholder. 
This practice is designed to prevent misrepresentation, known as “fronting”, where a more experienced 
driver is listed as the main policyholder, but a younger or riskier driver predominantly uses the vehicle. 
While we acknowledge that fronting was not a factor in this tragic accident, we have outlined below the 
steps that insurers take to help mitigate it. 

While there is currently no single, industry-wide methodology for identifying higher-than-expected use by 
named drivers, this is because it can be difficult to identify, and insurers are, to an extent, reliant on the 
honesty of their policyholders. Nevertheless, insurers do employ a range of tools and data sources to 
detect potential fronting, including analysing patterns of vehicle usage, monitoring claims histories, 
reviewing telematics data, and looking for inconsistencies in declared information. For instance, insurers 
might flag policies where a named driver appears to be using the vehicle far more frequently than the 
main policyholder, or where telematics data suggests driving habits do not match the profile of the 
declared main user. 

Telematics: Application and Communication 

Telematics technology has become a vital tool in promoting safer driving among young motorists, 
providing real-time feedback and incentivising positive driving behaviours. However, the use of 
telematics remains optional for motorists, and neither the ABI nor its members have the authority to 
mandate its adoption. Requiring telematics for all drivers could limit consumer choice and potentially 
increase the cost of cover for some individuals. Nevertheless, the ABI is committed to working with its 
members to continue championing the benefits of telematics, encouraging its uptake among new and 
novice drivers to help improve road safety.  

In addition to our work with insurers, the ABI collaborates with leading road safety charities, including 
BRAKE, RoSPA, and PACTS, to further strengthen our approach to telematics and its role in young driver 
safety. These partnerships enable us to draw upon expert knowledge and outreach capabilities to ensure 
that communications about telematics are both accurate and impactful, particularly in highlighting its 
potential to reduce risky driving behaviours and prevent accidents. 

Furthermore, our engagement with the Department for Transport is central to these efforts. The ABI 
participated in the Stakeholder Panel of the Government’s recent Motor Insurance Taskforce, where we 
advocated for the integration of telematics data into broader road safety initiatives.  

The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026 

 
 
 
 
 
 
 
 
 Through these collaborative actions, we aim to support insurers in explaining the role of telematics—not 
only as a tool for premium calculation, but also as a way to enhance road safety for young drivers and the 
wider community. 

Next Steps 

As part of our established workstreams and priorities, the ABI will: 

•  Continue to work with our members to promote the use of telematics products for young and 

novice drivers. 

•  Continue to advocate for young and novice driver safety to the Government as part of the Road 

Safety Strategy, including progressive licensing.  

•  Continue to collaborate with road safety partners and government to promote awareness of the 
risks faced by young drivers, and support broader initiatives to reduce road traffic fatalities 
among this group. 

•  Continue to campaign to raise awareness amongst young drivers of motor insurance frauds, such 
as fronting and ghost broking, working alongside stakeholders, including the Driver and Vehicle 
Standards Agency.    

We are committed to supporting the prevention of further tragedies and to playing our part in supporting 
safer outcomes for young drivers on the UK’s roads.  

For further information about our work or to discuss these actions in more detail, please contact the ABI 
through 

The ABI | The ABI’s Response to Report to Prevent Future Deaths | 05.02.2026