From an insurance industry standpoint, this risks prolonging a reactive model, where harm is addressed after the event rather than prevented at source. There remains a strong case for more explicit and enforceable obligations on technology companies to identify and remove fraudulent content before it reaches consumers. 

The ‘Respond’ pillar seeks to address longstanding issues in the treatment of fraud victims. The replacement of Action Fraud with a new Report Fraud service is a particularly important development, given widespread criticism of the previous reporting framework. If implemented effectively, this could improve both intelligence gathering and victim engagement.

The planned introduction of a Fraud Victims’ Charter in 2027, setting out clear standards for response times and victim care, is also a positive step. For insurers, greater clarity and consistency in how fraud cases are handled may help reinforce public confidence in the system, particularly in relation to reimbursement and claims handling. 

Beyond the three pillars, the strategy also signals a number of structural and legal reforms. The consolidation of fraud, economic crime and cyber capabilities within the National Police Service and the National Crime Agency should, in principle, enhance coordination and specialist expertise. The exploration of civil penalties as an alternative enforcement mechanism may also provide a more agile route to tackling certain forms of fraud.

In parallel, the introduction of the ‘failure to prevent fraud’ offence in September 2025 is likely to drive improved internal controls within large organisations, including insurers and their supply chains. The Government has also indicated that further calls for evidence will follow, particularly in relation to data sharing, anonymity in communications, and the overall evidence base on fraud – all areas where industry input will be critical. 

Ultimately, while the strategy represents a step forward, it does not yet fully resolve some of the structural challenges that enable fraud to flourish. The scale of the problem – costing the UK economy billions each year – raises legitimate questions about whether £250 million is sufficient, particularly in the absence of more decisive action on cross-sector data sharing and platform accountability.

For insurers, who continue to absorb a significant proportion of fraud-related losses, the strategy is a positive signal of intent, but one that will require sustained collaboration between government, regulators and industry to translate into meaningful impact. Further detail on these issues can be found in the full Keoghs article here.