MEMA Scope · Assessment

Do insurance brokers need FCA authorisation?

A firm arranges, places or advises on insurance policies for customers, usually earning commission from insurers or fees from customers. Review the initial view below and answer a few questions to refine it.

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Initial viewProvisional assessment

Potential regulated activity identified

Insurance distribution may require FCA authorisation

Arranging or advising on insurance needs authorisation or appointed representative status unless an exclusion applies.

Route to consider: Direct authorisation (full permission)

Insurance Distribution - Arranging

Why this was flagged

  • 1Arranging contracts of insurance, including helping with applications and placing cover, is a regulated activity.
  • 2Receiving commission from insurers is a common feature of regulated distribution.

Questions still to resolve

Answer to refine the view. The result updates as you go.

  • ?

    Do you give personal recommendations on which policy a customer should take?

  • ?

    Do you hold premiums or claims money for customers or insurers?

  • ?

    Do you operate under a network or principal that takes regulatory responsibility for you?

Regulatory basis to examine

Your next steps

  1. 1Decide between direct authorisation and appointed representative status
  2. 2Implement demands and needs and suitability processes
  3. 3Arrange professional indemnity insurance
  4. 4Set up complaints handling and Consumer Duty governance

Where applications for this model most often fall short

  • A documented demands and needs process
  • Professional indemnity insurance evidence
  • Fair value and product governance for the products you distribute
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This is an initial indication from published FCA material, not an FCA determination or legal advice.

Continue with a more detailed readiness assessment

If authorisation is required, check the firm’s governance, policies, resources and application preparedness.

Will the FCA Authorise Us?

MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.

About this business model

A firm arranges, places or advises on insurance policies for customers, usually earning commission from insurers or fees from customers.

Arranging or advising on insurance needs authorisation or appointed representative status unless an exclusion applies.

This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.

Insurance broker or intermediary: frequently asked questions

Do insurance brokers need FCA authorisation?

Arranging or advising on contracts of insurance are regulated activities. Insurance brokers need authorisation or appointed representative status, unless an exclusion applies.

What is the difference between advising and arranging insurance?

Arranging includes helping complete applications and placing cover. Advising means giving a personal recommendation on a specific policy, which brings suitability duties in ICOBS 5.

What could change the answer for insurance brokers?

Arranging or advising on insurance needs authorisation or appointed representative status unless an exclusion applies. It can change depending on the answers to questions such as: Do you give personal recommendations on which policy a customer should take? Do you hold premiums or claims money for customers or insurers? Do you operate under a network or principal that takes regulatory responsibility for you?

Which FCA rules should insurance brokers look at first?

Start with: Arranging deals in investments, including insurance; PERG 5: insurance distribution; Identifying client needs and advising. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for insurance brokers?

Decide between direct authorisation and appointed representative status. Implement demands and needs and suitability processes. Arrange professional indemnity insurance. Set up complaints handling and Consumer Duty governance.

Businesses we check

MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.

Want a consultant to look at your facts?

Book a free scoping call and we will map the permissions, evidence and timeline for your firm.