SPECIALIST SERVICES
FCA Regulated • ICOBS ComplianceCustomer, 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
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.
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.
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.
Comprehensive support from authorisation through ongoing compliance
End-to-end support for insurance broking authorisation
Embedding ICOBS requirements into your business
Continuous regulatory support for insurance brokers
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.
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.
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.
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.
Navigate the Insurance Conduct of Business Sourcebook requirements
Clear, compliant documentation for insurance customers
Acting in accordance with customer's best interests rule
Understanding and documenting customer requirements
Maintaining ICOBS compliance throughout the customer journey
The firm needs to understand its role in the product and customer chain.
Monitoring should assess outcomes and the commercial drivers around distribution.
Critical regulatory areas that every insurance broker must address
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.
Deeper reading on the regulatory framework behind insurance broking.
Two free MEMA tools for working out where a firm stands before it applies or changes its model.
Not yet authorised? Our sector page on insurance broker FCA authorisation covers the application route, and this page covers the compliance work that follows.
This service is available for firms across these regulated sectors
End-to-end support across the full regulatory lifecycle.
Common questions about insurance broker compliance
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.
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.
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.
An insurance broker compliance audit tests whether the firm's controls and customer files meet the rules that apply to it. We run this as a compliance health check with file review, and it looks at ICOBS conduct (the demands and needs test, disclosure and the reasons for any personal recommendation), training and competence, including the knowledge and ability arrangements that derive from the Insurance Distribution Directive, product governance and fair value under PROD 4 and Consumer Duty, complaints handling under DISP, and financial promotions. Where the firm holds client money, CASS 5 is reviewed too. The output is a set of findings the firm can evidence to the FCA, its board or a network principal.
Yes, if the broker holds client money under CASS 5, other than only as the insurer's agent under a risk transfer agreement (CASS 5.2): its auditor must then prepare a client assets report (SUP 3.10.4R). For insurance intermediaries the auditor sends the report to the firm within four months of the period end, and to the FCA on request (SUP 3.10.8AR). Brokers that hold no more than £30,000 of client money, and only on statutory trust (CASS 5.3), are exempt (SUP 3.1.2R, Note 4).
Contact our insurance broking specialists for expert FCA authorisation and ICOBS compliance support
Phone: 0330 133 0811
Email: contact@memaconsultants.com
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