Changing mortgage insurance: delegation, equivalence of guarantees, and the bank's response

Yes, you can change your mortgage insurance at any time. Since September 1, 2022, this applies to all borrowers, including those with an existing contract, without waiting until the end of the first year. Two conditions apply: the new contract must meet the guarantees required by your bank, and the bank must agree. If it refuses, it must communicate its refusal and justify it with a legitimate reason, such as the lack of equivalent coverage.

This page covers the switching procedure and the concept of equivalence. It does not quantify the potential savings: for an example of savings, see our blog post on the Lemoine Law. It also does not address the effective date of the termination of the old contract, nor the health questionnaire, which are covered on other pages.

What the rule says

The law that opened up this possibility is law no. 2022-270 of February 28, 2022 (source: economie.gouv.fr).

Choose an insurer other than the one offered by the bank

Your bank may offer you its own contract, but you remain free to choose the insurer of your choice. Changing insurers during the loan term means replacing your current contract with one taken out elsewhere.

If you choose an external contract, the bank cannot change the terms of the mortgage it offered or granted you. However, if you agree to the terms, the bank will amend the loan agreement with an addendum to indicate the new annual percentage rate (APR).

Equivalence of guarantees: what the bank checks

The personalized profile

When you signed the loan agreement, the bank gave you a personalized information sheet. It lists the minimum guarantees it requires. The new contract must comply with these requirements. Make sure you find it before taking any further steps.

According to service-public.gouv.fr, the elements of the form are defined using a maximum of 11 criteria for death, loss of autonomy, disability and incapacity guarantees, and a maximum of 4 criteria for job loss.

The equivalence criteria

To assess equivalence, the opinion of the Financial Sector Advisory Committee (CCSF) of April 18, 2017, indicates that the lender may choose a maximum of 11 criteria from the CCSF's limited list, relating to the risks of death, total and irreversible loss of autonomy (PTIA), disability, and incapacity. For job loss, note 3 of the opinion specifies a maximum of 4 criteria. The lender assesses the borrower's profile on a case-by-case basis. The opinion cites Article L313-30 of the Consumer Code: the lender cannot refuse another insurance contract provided that this contract offers an equivalent level of coverage.

Two reservations about this reference. The opinion dates from 2017 and is advisory: it is not a legal text. Furthermore, the list of criteria is not reproduced here: it can be found in the opinion itself. Article L313-30 is presented here exactly as the opinion quotes it: the text of the article has not been reviewed on Légifrance.

Job loss: optional coverage

According to service-public.gouv.fr, death coverage is always included in a mortgage insurance policy. Job loss coverage is different: you are free to choose whether or not to take it out, according to the service-public.gouv.fr information sheet on mortgage insurance. Your personalized loan information sheet specifies what your bank requires in your case.

The bank's deadlines

Two official pages mention a ten-day period. They do not link it to the same stage and do not formulate it in the same way.

The starting point is not defined in the same way: receipt of the complete file on one hand, receipt of the application on the other. This page does not explain how these two timeframes interact in your specific case: this point should be verified with the source before assigning a date.

If the bank refuses

The lender must state the reasons for the refusal. In this case, the current insurance contract is not terminated.

The CCSF's 2017 opinion goes in the same direction: refusals must be clearly justified, written and dated, and borrowers must be informed of the means of appeal, in particular via the letter of refusal.

Shipments to be planned

The official pages describe three shipments:

1. The complete file at the bank, with the new contract.
2. The cancellation request to the current insurer, in particular by letter or by act of a bailiff. According to economie.gouv.fr, article L113-14 of the Insurance Code provides for other methods, including letter or other durable medium and the same method of remote communication as the subscription.
3. Information from the new insurer You must inform them of the bank's decision by registered mail or electronic registered mail. You must also inform them of the effective date of the new contract accepted by the bank.

The exact timing of each transmission, and the effective date of the termination of the old contract, are not specified on the pages read. These details should be verified before sending anything.

Each year, the bank must also remind you of your right to cancel the borrower's insurance contract and how to exercise it.

Numerical example (fictitious profile)

Situation. Sophie took out a mortgage in 2025. She found an external insurance policy that seemed to cover the same risks as her bank's policy. She submitted a complete application on Monday, March 8, 2027.

Issue. She wants to know when she can expect a response from the bank. The economie.gouv.fr website states "10 days from receipt of the complete application" without specifying whether these are calendar days or working days.

Strategy. She retrieves her personalized file, compares each required guarantee with the proposed contract, and then submits a complete application. She notes the date of receipt and calculates the two possible counts.

Result. Calculation assumptions: complete file received on Monday, March 8, 2027; ten calendar days on the one hand; ten working days counted from Monday to Friday, without public holidays between March 9 and 22, 2027, on the other hand.

According to the calculation method used, a response can therefore be expected between March 18 and 22, 2027. This profile is fictitious. The calculation assumptions are those used in the calculation; they do not come from the official websites, which do not specify them. The 10-business-day processing time on service-public.gouv.fr, which applies to amendments after approval, is not included in this calculation. No savings or positive responses are expected.

What changes depending on your situation

• The content of your personalized profile : the guarantees required by your bank.
• Choosing job loss insurance, optional.
• The contents of your file : the receipt of the complete file is the starting point cited by economie.gouv.fr.
• The way your bank writes a potential refusal and the discrepancies in guarantees that it identifies.
• The termination terms stipulated in your current contract.

The rule depends on your situation and must be examined on a case-by-case basis. No results are guaranteed.