So if one was to look at setting up a database style site not unlike realestate.com, or hotel resort booking sites where users can go through a process of selecting what they want and dont want incorporated in their insurance coverage, or price range etc and then your site produces results based on their queries/selections....then I am thinking this would be classed as a comparison site?
I think the issue is that a few of them (online comparison sites) arent clearly disclosing which insurers are available in the database to begin with and claim to be comprehensive (wide range of insurers, or all of them) when in fact they are only dealing with a select few...Surely frontpage disclosure showing which insurers and their products are represented would keep ASIC happy on this, it shouldnt need to get complicated.