---
title: "Draft a Queensland insurer letter that reserves liability and quantum"
url: "https://ailawframework.com/practice/personal-injury-and-compensation/draft-correspondence-to-the-insurer-or-scheme-agent/queensland"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A21-T1-R13-QLD"
practice_area: "Personal Injury & Compensation (workers compensation, CTP/TAC, medical negligence)"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["QLD"]
last_reviewed: "2026-10-25"
---

# Draft a Queensland insurer letter that reserves liability and quantum

> Draft a letter to the CTP insurer, WorkCover Queensland, a self-insurer or a respondent from cited file documents and the outstanding list.

Canonical page: https://ailawframework.com/practice/personal-injury-and-compensation/draft-correspondence-to-the-insurer-or-scheme-agent/queensland  
Last reviewed: 2026-10-25

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Personal Injury & Compensation (workers compensation, CTP/TAC, medical negligence)](https://ailawframework.com/practice/personal-injury-and-compensation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Draft a letter to the CTP insurer, WorkCover Queensland, a self-insurer or a respondent from cited file documents and the outstanding list. |
| What the lawyer must review | Do not concede liability or quantum Check the recipient and any section 37 time if the letter is about the notice You settle every sentence before it is sent |
| Written for | Queensland |
| Applies to | [Draft correspondence to the insurer or scheme agent](https://ailawframework.com/practice/personal-injury-and-compensation/draft-correspondence-to-the-insurer-or-scheme-agent.md) |

## Checking plan

**Verify against sources**

The lawyer settles the letter. It does not concede liability or quantum and it does not replace the notice.

- What the AI does: Draft a letter to the CTP insurer, WorkCover Queensland, a self-insurer or a respondent from cited file documents and the outstanding list.
- What the lawyer does: Make the legal assessment, check the source material and authorise the output for its intended use.
- Who reviews: Lawyer competent in this practice area
- Basis: Checked against the linked sources on 23 October 2026. Confirm the current instrument before reliance.

## Checks the lawyer makes

1. Name the recipient the file supports: the licensed CTP insurer, the Nominal Defendant where section 37 requires it, WorkCover Queensland or a self-insurer, or the Personal Injuries Proceedings Act respondent.
2. Cite only documents that are on the file. List outstanding items separately. Do not concede liability or a figure for quantum.
3. If the letter concerns a motor accident notice, check section 37. Notice to the Nominal Defendant for an unidentified vehicle is three months. Otherwise it is due on the earlier of two days. The first is the day 9 months after the accident or, if symptoms were not immediately apparent, the first appearance of symptoms. The second is the day 1 month after the claimant first consults a lawyer about the possibility of making a claim. An unidentified vehicle not notified within nine months is barred. A late notice otherwise continues, and a reasonable excuse is given in the notice or by separate notice.
4. Do not invent a deadline for the recipient to answer. The letter is not the notice of claim.

## Notes

- Section 6 of the Personal Injuries Proceedings Act takes a Motor Accident Insurance Act injury, and chapter 5 damages against an employer, outside that Act. The letter follows the Act that applies.
- The letter is sent to another party. The lawyer checks it before it goes. Practice Direction 5 of 2025 or Practice Direction 12 of 2025 applies if the letter is later filed.

## Practical guide

Jurisdiction: Queensland plaintiff claims against a CTP insurer, WorkCover Queensland, a self-insurer, or a Personal Injuries Proceedings Act respondent.

**Deliverable**: A letter the insurer or respondent receives, after the lawyer settles every sentence.

**Inputs**

- Cited file documents
- The outstanding-item list
- The correct recipient and the Act

**Example**: Illustrative example: The draft says the insurer has admitted a percentage of liability. The file does not say that. The lawyer deletes the sentence before the letter is sent.

**Stop and escalate when**

- The letter concedes liability or quantum.
- The recipient or the Act is uncertain.

Checked 2026-10-23.

## Sources

- [Motor Accident Insurance Act 1994 (Qld), section 37](https://www.legislation.qld.gov.au/view/whole/html/current/act-1994-009) (checked 2026-10-23)
- [Personal Injuries Proceedings Act 2002 (Qld), section 6](https://www.legislation.qld.gov.au/view/whole/html/current/act-2002-024) (checked 2026-10-23)
- [Workers' Compensation and Rehabilitation Act 2003 (Qld), section 275](https://www.legislation.qld.gov.au/view/whole/html/current/act-2003-027) (checked 2026-10-23)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Letter to an occupier and its insurer: notice of an injury and a liability response](https://ailawframework.com/precedents/personal-injury-and-compensation/occupier-insurer-injury-notice-letter.md) | Letter | Yellow | A plaintiff firm's letter telling an occupier and its public liability insurer about an injury, asking for the insurer's details and a liability response, and asking that footage and incident… |
| [Offer of compromise in personal injury proceedings (UCPR r 20.26, NSW), with covering letter](https://ailawframework.com/precedents/personal-injury-and-compensation/offer-of-compromise-personal-injury-nsw.md) | Notice | Yellow | Plaintiff's or defendant's formal offer of compromise under r 20.26 of the Uniform Civil Procedure Rules 2005 (NSW), with the mandatory contents, the acceptance period, and a covering letter… |
| [Request for NIISQ lifetime participation before the two-year anniversary](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-niisq-lifetime-participation-request.md) | Letter | Yellow | Letter asking the National Injury Insurance Agency, Queensland to repeat an interim participant's eligibility review before the two-year anniversary and to say whether lifetime participation is… |
| [Mandatory final offer under the Personal Injuries Proceedings Act 2002 (Qld)](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-pipa-mandatory-final-offer.md) | Notice | Yellow | The claimant's mandatory final offer under sections 39 and 40 of the Personal Injuries Proceedings Act 2002 (Qld).… |
| [Letter of representation and preservation](https://ailawframework.com/precedents/personal-injury-and-compensation/us-representation-preservation-letter.md) | Letter | Yellow | Notice that a lawyer represents an injured person, and a request that the recipient keep records and electronically stored information about the incident. |
| [Offer of compromise in a personal injury proceeding (Order 26, Victoria)](https://ailawframework.com/precedents/personal-injury-and-compensation/vic-offer-of-compromise-personal-injury.md) | Notice | Yellow | Plaintiff offer of compromise for a Victorian personal injury claim. If the plaintiff beats the offer, rule 26.08(2)(a) gives the plaintiff's costs of the claim taxed on an indemnity basis unless… |
| [Letter to a former employer: employment history and the workers compensation insurer](https://ailawframework.com/precedents/personal-injury-and-compensation/letter-former-employer-dust-history-insurer.md) | Letter | Yellow | A letter asking a former employer for the client's dates, job, sites, dust products, and the workers compensation insurer or self-insurer for those years. |
| [Mandatory final offer under the Motor Accident Insurance Act 1994 (Qld)](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-motor-accident-mandatory-final-offer.md) | Notice | Yellow | The claimant's mandatory final offer under section 51C of the Motor Accident Insurance Act 1994 (Qld). It stays open for 14 days. |
| [Covering letter for NIISQ internal review of eligibility or treatment, care and support](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-niisq-internal-review-request.md) | Letter | Yellow | Covering letter for the NIISQ internal review form, with eligibility and treatment, care and support kept apart. It is not an application to the Workers' Compensation Regulator. |
| [Offer to settle a personal injury proceeding (UCPR rr 353, 355, 357 and 360, Queensland)](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-offer-to-settle-personal-injury.md) | Notice | Yellow | Plaintiff offer to settle a Queensland personal injury proceeding under UCPR r 353.… |
| [Without-prejudice Calderbank letter (Victoria, Queensland and New South Wales)](https://ailawframework.com/precedents/personal-injury-and-compensation/calderbank-letter-personal-injury.md) | Letter | Yellow | A without-prejudice letter offering to settle a personal injury claim, with a statement that the plaintiff will rely on it on costs if the offer is not accepted. It is not a rules offer. |
| [Letter to an employer asking for incident documents, a footage hold and wage records](https://ailawframework.com/precedents/personal-injury-and-compensation/employer-incident-and-wages-letter.md) | Letter | Yellow | A letter, with the worker's authority, asking an employer for time and wage records and for the incident report, and asking the employer to keep any footage of the incident.… |
| [Additional information form (MAIC Form F2)](https://ailawframework.com/precedents/personal-injury-and-compensation/form-qld-maic-additional-information.md) | Form | Yellow | Link to MAIC Form F2 V7 Apr 2022. Section 37A requires the claimant to return the approved additional information form within 1 month after the insurer asks. |
| [Lifetime Care eligibility dispute, and request to review an assessment panel decision](https://ailawframework.com/precedents/personal-injury-and-compensation/nsw-lifetime-care-eligibility-dispute.md) | Letter | Yellow | Letter disputing a Lifetime Care eligibility decision, with a separate written request to review an assessment panel decision on the four grounds the icare page lists. |
| [Letter asking that footage, photographs and physical evidence be preserved](https://ailawframework.com/precedents/personal-injury-and-compensation/cctv-and-evidence-preservation-letter.md) | Letter | Yellow | A letter asking the person who holds footage or a physical item to stop it being overwritten, deleted or repaired, and to say whether it still exists.… |
| [Review form (SIRA): ask the insurer to review a work capacity or liability decision](https://ailawframework.com/precedents/personal-injury-and-compensation/form-nsw-sira-insurer-review.md) | Form | Yellow | Link to SIRA's review form. It includes the 14-day insurer review and the stay of weekly payments. |
| [Letter of claim to a public health service, including an initial notice](https://ailawframework.com/precedents/personal-injury-and-compensation/letter-of-claim-public-health-service.md) | Letter | Yellow | Letter of claim to a public health service. In Queensland it is an initial notice under the Personal Injuries Proceedings Act 2002 s 9A, and the Victorian and New South Wales variants ask the… |
| [Request for Lifetime Care lifetime participation near the end of the two years](https://ailawframework.com/precedents/personal-injury-and-compensation/nsw-lifetime-care-lifetime-participation-request.md) | Letter | Yellow | Letter from an interim Lifetime Care participant asking to be accepted for lifetime participation near the end of the two years, with the injury criteria the who-we-care-for page states. |
| [Settlement offer and assessment-conference paper for a NSW motor accident damages claim](https://ailawframework.com/precedents/personal-injury-and-compensation/nsw-motor-accident-settlement-offer.md) | Letter | Yellow | The claimant's written settlement offer on a damages claim under the Motor Accident Injuries Act 2017 (NSW), and a short paper for the Commission assessment conference.… |
| [Motor accidents dispute application (Personal Injury Commission Pathway)](https://ailawframework.com/precedents/personal-injury-and-compensation/form-nsw-pic-motor-accidents-application.md) | Form | Yellow | Link to the Personal Injury Commission's Pathway application for a motor accidents dispute, including who may apply, what the other parties can see, and the schedule of earnings for merit review. |
| [Request to a scheme insurer for written reasons and the documents relied on](https://ailawframework.com/precedents/personal-injury-and-compensation/scheme-reasons-and-documents-request.md) | Letter | Yellow | A letter asking a statutory insurer for the reasons for a decision and the documents relied on, using the request that exists for that scheme, with a cover for the Transport Accident Commission… |
| [Request to the Transport Accident Commission for attendant care or post-acute support](https://ailawframework.com/precedents/personal-injury-and-compensation/vic-tac-attendant-care-request.md) | Letter | Yellow | Letter asking the Transport Accident Commission to fund attendant care or post-acute support after a transport accident. The opened policy does not describe a separate lifetime support scheme. |
| [Response to an insurer's denial of liability](https://ailawframework.com/precedents/personal-injury-and-compensation/response-to-denial-of-liability.md) | Letter | Yellow | A letter identifying an insurer's denial, stating the facts the client disputes, asking for reconsideration, and listing documents still missing.… |
| [Conference paper and offer under the TAC Common Law Protocol 2026](https://ailawframework.com/precedents/personal-injury-and-compensation/vic-tac-common-law-conference-paper.md) | Memo | Yellow | The client's paper and written offer for a serious injury conference or a common law damages conference under the TAC Common Law Protocol 2026.… |
| [Request for a review of a New South Wales motor accident or workers compensation decision](https://ailawframework.com/precedents/personal-injury-and-compensation/nsw-insurer-review-request.md) | Letter | Yellow | A New South Wales letter asking a motor accident insurer for an internal review, or a workers compensation insurer for a review under section 287A. The motor accident part may be sent as a letter. |
| [Complaint to the Independent Review Office about a workers compensation or CTP insurer](https://ailawframework.com/precedents/personal-injury-and-compensation/nsw-iro-insurer-complaint.md) | Letter | Yellow | Letter for a complaint to the New South Wales Independent Review Office about a workers compensation insurer or a CTP insurer, with the two pathways kept apart. |
| [Statutory counter offer before a Victorian serious injury damages proceeding](https://ailawframework.com/precedents/personal-injury-and-compensation/vic-worksafe-statutory-counter-offer.md) | Letter | Yellow | The worker's statutory counter offer under section 333 of the Workplace Injury Rehabilitation and Compensation Act 2013 (Vic).… |
| [Covering letter for an application to review a Queensland workers' compensation decision](https://ailawframework.com/precedents/personal-injury-and-compensation/qld-workers-compensation-review-letter.md) | Letter | Yellow | A covering letter for the approved application to the Workers' Compensation Regulator, with draft grounds, the documents to be considered, and a request for reasons where the notice gave none.… |
| [Reply to a Calderbank offer in a personal injury claim](https://ailawframework.com/precedents/personal-injury-and-compensation/reply-to-calderbank-offer.md) | Letter | Yellow | A reply to a Calderbank offer in a Victorian, Queensland or New South Wales personal injury claim. It identifies unclear terms and the time allowed, and in Victoria it uses the Hazeldene list only. |
| [Letter to a scheme case manager](https://ailawframework.com/precedents/personal-injury-and-compensation/scheme-case-manager-introduction.md) | Letter | Yellow | Letter telling a scheme or insurer case manager that the firm acts, who to contact, and which authority is enclosed. It is not a claim form and not a WorkCover third-party file release. |
| [Letter to the payer sending a personal injury deed and payment terms](https://ailawframework.com/precedents/personal-injury-and-compensation/settlement-implementation-letter-to-payer.md) | Letter | Yellow | Letter to the payer's solicitors sending a personal injury deed and stating when the compensation may be paid, including the Medicare hold on any payment to the injured person. |
| [Covering letter for a Workplace Injury Commission conciliation application](https://ailawframework.com/precedents/personal-injury-and-compensation/vic-wic-conciliation-covering-letter.md) | Letter | Yellow | Covering letter sent with a Workplace Injury Commission Application for Conciliation. The worker or an authorised helper completes the form, and the tool does not sign it. |
| [Notice of claim for damages (WorkCover Form 275)](https://ailawframework.com/precedents/personal-injury-and-compensation/form-qld-wc-notice-of-claim-damages.md) | Form | Yellow | Link to Form 275, version 3, the approved notice of claim for damages under section 275. Statements in the claimant's personal knowledge must be verified by statutory declaration. |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*