MEMA Scope · Assessment

Do insurance introducers need FCA authorisation?

A business, such as a retailer or membership organisation, mentions insurance to its customers or refers them to an insurer or broker, without arranging or advising on cover. Review the initial view below and answer a few questions to refine it.

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FCA rule references
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Initial viewProvisional assessment

Exclusion or exemption may apply

Insurance introductions may be excluded, but only if you stay within limits

Merely providing information, or introducing customers without helping with the application, may fall within exclusions. Doing more can make you an insurance intermediary.

Route to consider: May fall outside the perimeter if an exclusion applies

Insurance - Introducer / Information Only

Why this was flagged

1Referring customers to an insurer or broker can be arranging if done under an ongoing arrangement.
2The exclusions for giving information are narrow and depend on exactly what you do.

Questions still to resolve

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

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Do you help customers complete application forms, compare policies or recommend a product?
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Do you have an ongoing arrangement with one insurer or broker, and are paid per customer introduced?
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Do you only provide generic information about insurance, or about the insurer’s contact details, and take no payment tied to sales?

Regulatory basis to examine

RAO Art.33B Provision of information, insurance (exclusion)Provision of information, insurance (exclusion)RAO Art.72C Provision of information on an incidental basisProvision of information on an incidental basis PERG 5 Guidance on insurance distribution activitiesPERG 5: insurance distribution

Your next steps

1Write down exactly what your staff say and do when insurance is raised
2Test your activity against the information-only exclusions
3Do not help with applications, compare products or recommend cover unless authorised
4Get a written view before relying on an exclusion

Where applications for this model most often fall short

A script and process showing you stay within information-only limits
Commercial terms showing how you are paid
A decision on whether appointed representative status is preferable

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This is an initial indication from published FCA material, not an FCA determination or legal advice.

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How Compass helps

Ask about an activity, exclusion or FCA requirement. Answers come only from vetted profiles, FCA Handbook and legislation extracts and MEMA guidance, and every answer cites its source.

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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 business, such as a retailer or membership organisation, mentions insurance to its customers or refers them to an insurer or broker, without arranging or advising on cover.

Merely providing information, or introducing customers without helping with the application, may fall within exclusions. Doing more can make you an insurance intermediary.

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 introducer or affinity partner: frequently asked questions

Do insurance introducers need FCA authorisation?

Merely providing information about insurance may fall within exclusions in RAO Arts.33B and 72C. But introducing customers to an insurer or intermediary under an ongoing arrangement can be arranging, and helping with applications is not excluded.

Can a retailer or letting agent sell insurance without FCA authorisation?

Only if its activity stays within an exclusion. If it helps customers apply, compares products or recommends cover, it may need authorisation or appointed representative status.

What could change the answer for insurance introducers?

Merely providing information, or introducing customers without helping with the application, may fall within exclusions. Doing more can make you an insurance intermediary. It can change depending on the answers to questions such as: Do you help customers complete application forms, compare policies or recommend a product? Do you have an ongoing arrangement with one insurer or broker, and are paid per customer introduced? Do you only provide generic information about insurance, or about the insurer’s contact details, and take no payment tied to sales?

Which FCA rules should insurance introducers look at first?

Start with: Provision of information, insurance (exclusion); Provision of information on an incidental basis; PERG 5: insurance distribution. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for insurance introducers?

Write down exactly what your staff say and do when insurance is raised. Test your activity against the information-only exclusions. Do not help with applications, compare products or recommend cover unless authorised. Get a written view before relying on an exclusion.

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.