FCA Authorisation for Insurance Brokers

What the FCA assesses for an insurance intermediary

Insurance intermediaries are authorised under FSMA to carry on insurance distribution, with conduct standards in ICOBS and the IDD-derived requirements. The FCA expects appropriate knowledge and ability, product oversight and governance, professional indemnity cover at the MIPRU minimums and capital set by MIPRU 4. An application covering insurance distribution only runs on a shorter statutory clock: the FCA must decide a complete one within 3 months, not the usual 6.

The 12 questions in this check

1. Business Model & Scope

   Do you have a clear business plan and target market for the permissions you want?

   The FCA expects firms to clearly define their target market and show how the business model supports good customer outcomes and regulatory compliance.

2. Business Model & Scope

   Are the regulatory permissions you are applying for correctly scoped for what you will actually do?

   Applications are commonly delayed when the permissions requested are broader than the business model, or miss activities the firm will carry on.

3. People & Accountability

   Do you have people with the right experience for the senior roles your regime requires?

   The regulator assesses whether the individuals running the activity are competent, capable and fit and proper, with responsibilities clearly allocated (under the SM&CR, the PSD/e-money individual regime or the money laundering rules, depending on your activity).

4. Financial Resources & Safeguarding

   Do you have the capital, safeguarding approach, and financial resources documented for the activity you want to carry on?

   The FCA expects appropriate capital planning, safeguarding arrangements (where relevant) and evidence of sufficient financial resources to support the proposed activity.

5. Compliance Oversight

   Do you have ongoing compliance oversight, monitoring, and complaints handling in place?

   The FCA expects clear responsibility for compliance, active monitoring of risk and controls, and effective arrangements for handling customer complaints.

6. Systems & Controls

   Do you have the systems, records and financial crime controls the activity requires?

   Firms must evidence adequate systems and controls, record keeping, and (where in scope) financial crime and AML arrangements proportionate to the business.

7. Governance & Accountability

   Is there clear board or senior management oversight and accountability for the regulated business?

   The regulator expects governance arrangements that give senior management effective oversight, with clear individual accountability.

8. Ownership & Establishment

   Have you mapped your controllers and beneficial owners, and is the firm's mind and management in the UK?

   The FCA assesses controllers, beneficial owners and group structure, and expects the firm to be capable of effective supervision with its head office and key functions in the UK (a Threshold Condition, or the equivalent condition under the PSRs/EMRs/MLRs).

9. Application Readiness

   Are your application pack and supporting documents drafted and ready to submit?

   A complete, consistent application pack with the required supporting documents materially reduces the risk of delay or a request for more information.

10. Professional Indemnity

    Do you hold, or have quotes for, professional indemnity insurance at the required minimum levels?

    Insurance intermediaries must hold professional indemnity insurance at the MIPRU minimum levels; adequate cover is a condition of authorisation.

11. Knowledge & Product Oversight

    Can you evidence IDD knowledge and ability, and product oversight and governance arrangements?

    Relevant staff must meet knowledge and ability requirements with appropriate ongoing training (the fixed 15-hour CPD minimum was removed in December 2025), and firms must operate PROD product oversight and governance.

12. Client Money

    Will you hold client money (premiums), and if so are your CASS 5 or risk-transfer arrangements documented?

    Many intermediaries hold client money; whether you do affects your permissions, prudential requirements and audit, so the FCA expects clear CASS 5 or risk-transfer arrangements.

Common pitfalls

• Professional indemnity insurance below the MIPRU 3.2.7R minimum limits, or with exclusions that leave the regulated business uncovered
• Knowledge and ability (IDD training) not evidenced
• Product oversight and governance arrangements missing

Read more on our FCA authorisation service, see how we support insurance firms, or work through the full authorisation readiness checklist.