FCA Regulated • ICOBS Compliance

Insurance Broker Compliance Consultants

Expert support for insurance brokers navigating FCA authorisation and ICOBS regulation. We help you meet regulatory requirements, maintain compliance, and grow your insurance mediation business with confidence.

Get Insurance Broking SupportCall: 0330 133 0811

The Insurance Broking Compliance journey

The route from scoping your permissions to a decision. The FCA's part of it is fixed; the preparation before it is where applications are won or lost.

Establish your distribution role

Broker, managing general agent and appointed representative are different positions in the distribution chain, with different permissions and different responsibilities.

  • Confirm which insurance distribution activities you carry on
  • Map your position in the distribution chain
  • Establish whether you handle client money
What applies
Insurance distribution
Where it sits in the rules
ICOBS sourcebook
FCA determination
6–12 months

Statutory period from a complete application

FCA application fee
£2,820

Published pricing category

What needs to be strengthened?

Select the part of insurance distribution where evidence or ownership needs attention.

Authorisation

Clarify permissions, roles and regulated activities.

Key Insurance Broking Compliance Requirements

What the FCA expects, and the evidence behind it.

Distribution roleDefine manufacturer, distributor and intermediary responsibilities.
Customer needsEvidence demands, needs and clear communications.
Fair valueReview product, remuneration and customer value.
MonitoringTest files, complaints and outcomes.

What you will need to produce

  • Insurance permissions and distribution map
  • Demands and needs framework
  • Product governance and fair-value evidence
  • File review, complaints and monitoring

Set distribution responsibilities

The firm needs to understand its role in the product and customer chain.

ICOBS scope

Map demands and needs, advice, information, mid-term changes and claims interactions.

Manufacturer and distributor

Set information, due-diligence, product-governance and escalation responsibilities.

Customer needs

Connect product choice, customer understanding, vulnerability and service support.

Test value and oversight

Monitoring should assess outcomes and the commercial drivers around distribution.

Fair value

Review product benefits, price, commission, add-ons and customer outcomes.

Controls

Include financial promotions, CASS 5 where relevant and complaints under DISP.

File monitoring

Test live files, communications, complaints and the closure of identified issues.

What Insurance Broker Compliance Involves

FCA compliance for insurance brokers is governed principally by the Insurance Conduct of Business sourcebook (ICOBS), the product governance rules in PROD 4, and Consumer Duty. Here is what it involves in practice.

1. Demands and needs, and suitability

Every insurance sale must be consistent with the customer's demands and needs under ICOBS 5. Where advice is given, the recommendation must be suitable. Firms must evidence how the product matches the customer and keep records that stand up to FCA review.

2. Fair value and Consumer Duty

The product governance rules in PROD 4 and Consumer Duty require firms to assess and evidence that products deliver fair value to customers. This is a particular FCA focus for brokers, including the scrutiny of commission and the pricing of add-on products. We help brokers run and document their fair value assessments.

3. Client money, governance and reporting

Insurance brokers that handle client money must comply with CASS 5, alongside their SMCR obligations, compliant financial promotions, complaints handling under DISP, and accurate regulatory returns. Our consultants build and maintain the framework so these obligations are met continuously.

How MEMA Supports Insurance Brokers

Comprehensive support from authorisation through ongoing compliance

  1. 01

    FCA Authorisation

    End-to-end support for insurance broking authorisation

    • Application preparation and submission
    • Business plan development
    • PI insurance arrangement guidance
    • Capital adequacy calculations
    • FCA liaison and correspondence
  2. 02

    ICOBS Implementation

    Embedding ICOBS requirements into your business

    • Policy and procedure drafting
    • Documentation template creation
    • Staff training programmes
    • Compliance monitoring frameworks
    • Regular compliance reviews
  3. 03

    Ongoing Advisory

    Continuous regulatory support for insurance brokers

    • Regulatory change updates
    • Compliance health checks
    • FCA correspondence support
    • Remediation project assistance
    • Strategic compliance planning

FCA Authorisation for Insurance Brokers

Key requirements and prerequisites for insurance mediation authorisation

Professional Indemnity Insurance

Mandatory PI insurance coverage for all insurance brokers

  • Minimum coverage levels required
  • Policy must meet FCA standards
  • Annual renewal obligations
  • Run-off cover considerations

Capital Requirements

Financial resources to support your insurance business

  • Base capital requirements
  • Additional capital for permissions
  • Ongoing financial monitoring
  • Wind-down planning

Competence & Qualifications

Appropriate skills and knowledge for insurance mediation

  • Relevant insurance qualifications
  • SM&CR certification requirements
  • Continuing professional development
  • Training and competence schemes

Policies & Procedures

Comprehensive documentation framework

  • ICOBS-compliant policies
  • Customer documentation
  • Complaints handling procedures
  • Records retention policies

Compliance Monitoring

Ongoing oversight of regulatory obligations

  • Regular compliance reviews
  • MI and reporting frameworks
  • Internal audit programmes
  • Risk assessment updates

Consumer Duty Compliance

Meeting FCA's consumer protection standards

  • Fair value assessments
  • Customer outcome monitoring
  • Product governance frameworks
  • Vulnerability considerations

ICOBS Compliance Support

Navigate the Insurance Conduct of Business Sourcebook requirements

Customer Documentation

Clear, compliant documentation for insurance customers

  • Terms of business letters
  • Initial disclosure documents
  • Suitability reports
  • Product information documents

Customer's Best Interests

Acting in accordance with customer's best interests rule

  • Fair value assessments
  • Product selection frameworks
  • Remuneration disclosure
  • Conflict of interest management

Demands & Needs Analysis

Understanding and documenting customer requirements

  • Fact-find templates
  • Needs assessment procedures
  • Suitability demonstration
  • Documentation standards

Ongoing Compliance

Maintaining ICOBS compliance throughout the customer journey

  • Mid-term adjustments
  • Renewal procedures
  • Claims handling support
  • Regular compliance reviews

Essential Compliance for Insurance Brokers

Critical regulatory areas that every insurance broker must address

Professional indemnity insurance
ICOBS conduct requirements
Consumer Duty compliance
SM&CR responsibilities
Financial crime controls
Complaints handling procedures

Sectors We Support

This service is available for firms across these regulated sectors

Insurance Brokers

Related FCA Guidance

Deeper reading on the regulatory framework behind insurance broking.

Sector

Insurance Fair Value

How the FCA assesses fair value in insurance products under Consumer Duty.

Handbook

COBS: Conduct of Business

The FCA conduct rules governing client interactions, suitability, and disclosure.

Implementation

FCA Authorisation Preparation

Step-by-step guide to preparing a complete FCA authorisation application.

Frequently Asked Questions

Common questions about insurance broker compliance

Do insurance brokers need to be FCA authorised?

Yes. Arranging, advising on or dealing in general insurance contracts is a regulated activity, so insurance brokers and intermediaries must be directly authorised by the FCA or act as an appointed representative of a principal firm. Section 19 FSMA prohibits carrying on insurance mediation without the right permission, and section 23 makes contravening that prohibition a criminal offence. MEMA prepares insurance broker authorisation applications and advises on the appointed representative route where appropriate.

What is ICOBS?

ICOBS is the FCA's Insurance Conduct of Business sourcebook, which governs how firms sell and administer general insurance. It covers the demands-and-needs assessment, pre-contract disclosure, information about the product and any advice given, and the handling of mid-term changes and claims. ICOBS sits alongside the product governance rules in PROD 4 and Consumer Duty, and brokers must be able to evidence compliance across the customer journey.

What does Consumer Duty mean for insurance brokers?

Consumer Duty requires insurance brokers to deliver and evidence good customer outcomes, not just follow ICOBS process. The fair value obligations are a particular FCA focus for brokers, including scrutiny of commission levels and the pricing of add-on products. In practice brokers need documented fair value assessments, clear customer communications, and management information that shows outcomes are monitored across the book.

Do you offer ongoing compliance support for insurance brokers?

Yes. Alongside FCA authorisation and ICOBS implementation, MEMA provides ongoing compliance support for insurance brokers: fair value and product governance reviews, client money (CASS 5) oversight, financial promotion sign-off, complaints handling under DISP, SM&CR administration and regulatory reporting. Retained support gives smaller brokers ex-FCA expertise without the cost of a full-time compliance team.

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Phone: 0330 133 0811

Email: contact@memaconsultants.com