SPECIALIST SERVICES
FCA Regulated • ICOBS ComplianceInsurance Broker Compliance Consultants
Customer, product and monitoring controls for insurance distribution.
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.
SERVICE OVERVIEW
Insurance Broking Authorisation and Compliance
Build insurance distribution controls around customers, product governance and the broker's real role.
Insurance brokers and intermediaries reviewing authorisation, ICOBS or Consumer Duty controls. A clear broking model with practical customer, product and monitoring evidence.
Evidence we help you build
- Insurance permissions and distribution map
- Demands and needs framework
- Product governance and fair-value evidence
- File review, complaints and monitoring
Typical timeframe
Ready to submit within 6 weeks, often sooner
Under FSMA the FCA must decide within 6 months of receiving a complete application, or within 12 months of receiving an incomplete one.
Ideal for
- Insurance brokers
- Intermediaries
- Firms reviewing authorisation, ICOBS or Consumer Duty controls
What needs to be strengthened?
- Authorisation
- Customer documentation
- Product governance
- Monitoring
How MEMA helps you
- FCA Authorisation
- ICOBS Implementation
- Ongoing Advisory
What needs to be strengthened?
Select the part of insurance distribution where evidence or ownership needs attention.
Authorisation
Clarify permissions, roles and regulated activities.
Customer documentation
Review demands, needs and communications.
Product governance
Connect target market, value and distribution.
Monitoring
Test files, conduct and ongoing controls.
How MEMA Supports Insurance Brokers
Comprehensive support from authorisation through ongoing compliance
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
ICOBS Implementation
Embedding ICOBS requirements into your business
- Policy and procedure drafting
- Documentation template creation
- Staff training programmes
- Compliance monitoring frameworks
- Regular compliance reviews
Ongoing Advisory
Continuous regulatory support for insurance brokers
- Regulatory change updates
- Compliance health checks
- FCA correspondence support
- Remediation project assistance
- Strategic compliance planning
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.
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
- Demands and needs statements, with the reasons for any personal recommendation
- Insurance product information documents (IPIDs)
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
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.
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
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.
- 1Establish your distribution roleBroker, 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
- 2Evidence demands, needs and fair valueThese applications turn on product governance and on the customer's demands and needs being demonstrably met rather than asserted.
- Build the demands and needs process
- Prepare product governance and fair-value evidence
- Set up file review, complaints and monitoring
- 3Submit to FCASubmitted through the FCA's Connect portal with the application fee of £2,820.
- Complete submission through Connect
- Application fee paid at submission
- Case officer assigned by the FCA
- 4FCA reviewThe statutory determination period is 6–12 months — six months for a complete application, twelve if it is incomplete when submitted.
- Case officer raises questions on the submission
- Further information requests answered and evidenced
- Weak responses, not complexity, are the common cause of delay
- 5Permission grantedPermission is granted and the firm can carry on the regulated activity, subject to any requirements attached to it.
- Permission recorded on the Financial Services Register
- Any limitations or requirements confirmed
- Reporting and supervision obligations begin
Related FCA Guidance
Deeper reading on the regulatory framework behind insurance broking.
Sectors We Support
This service is available for firms across these regulated sectors
Explore our other services
End-to-end support across the full regulatory lifecycle.
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.
Ready to Get FCA Authorised for Insurance Broking?
Contact our insurance broking specialists for expert FCA authorisation and ICOBS compliance support
Phone: 0330 133 0811
Email: contact@memaconsultants.com