An FCA-regulated insurance broker should be able to answer 41 questions with evidence, not assertion: whether it holds the right permissions and resources, sells suitably, delivers fair value, handles claims and complaints properly, protects client money, keeps its people competent and files its returns on time. This checklist sets out each check, the rule behind it and the evidence a supervisor or auditor will ask for.
The rules changed more in the last year than in the previous five. On 9 December 2025, PS25/21 removed the 15-hour CPD minimum and the 12-month product review rule, introduced a "larger commercial customer" test and let insurers act as sole lead manufacturer. Further proposals in CP26/22 and CP26/23 are still open. Use this checklist alongside our tracker of FCA insurance rule changes.
1. Permissions, resources and governance
| Check | Rule | Evidence |
|---|---|---|
| Permissions on the Register match every activity, including premium finance and claims handling | Part 4A FSMA; PERG 5 | Register extract mapped to products and services |
| Threshold conditions met: adequate resources, suitability, effective supervision | COND 2 | Board-approved business plan and resource review |
| Capital resources at or above the MIPRU 4 requirement | MIPRU 4 | Quarterly capital calculation, reconciled to the RMAR |
| Professional indemnity insurance in force at the required limits | MIPRU 3 | Current policy schedule and renewal date |
| Appointed representatives approved, overseen and recorded | SUP 12 | AR register, annual self-assessment, monitoring records |
2. Sales and customer information
| Check | Rule | Evidence |
|---|---|---|
| Demands and needs identified before each sale | ICOBS 5.2 | Sample of sale files with recorded demands and needs |
| Advised sales are suitable for the customer | ICOBS 5.3 | Suitability letters and file review scores |
| Product information, including the IPID for retail customers, given in good time | ICOBS 6 | Customer documents with dates of issue |
| Commission disclosed to commercial customers on request, including all forms of remuneration | ICOBS 4.4.1R and 4.4.2G | Disclosure log and template responses |
| Policy price shown separately from premium finance costs | ICOBS 6.1.5R and 6.1.6G | Quotation and finance documents |
| Renewal pricing rules applied for home and motor, where the broker sets prices or fees | ICOBS 6B | Pricing policy and renewal file sample |
3. Consumer Duty and product governance
| Check | Rule | Evidence |
|---|---|---|
| Duty scope mapped, including the larger commercial customer test | PRIN 2A; PS25/21 | Scope map by product and customer type (our guide) |
| Distributor obligations met for each product: target market, distribution strategy, product information from the manufacturer | PROD 4.3 | Product files and manufacturer information packs |
| Remuneration consistent with fair value, including commission, fees and add-ons | PROD 4.3; PRIN 2A | Remuneration assessment (our method) |
| Review frequency set by risk and recorded for each distribution arrangement | PROD 4, as amended by PS25/21 | Review schedule with rationale |
| Consumer understanding tested for key communications | PRIN 2A.5 | Testing results and changes made |
| Customers with characteristics of vulnerability identified and supported | PRIN 2A; FG21/1 | Vulnerability policy, MI and case examples |
| Board review of customer outcomes at least once a year | PRIN 2A.8 | Board report and minutes showing challenge |
4. Claims
| Check | Rule | Evidence |
|---|---|---|
| Claims handled promptly and fairly where the broker acts for the customer | ICOBS 8; PRIN 2A.6 | Claims log with timescales |
| Conflicts managed where the broker also acts for the insurer under delegated authority | SYSC 10; ICOBS 8.3 | Conflicts register and procedures |
| Claims outcomes monitored for poor outcomes and vulnerable customers | PRIN 2A.6 | Claims MI and actions |
5. Complaints
| Check | Rule | Evidence |
|---|---|---|
| Complaints procedure published and followed | DISP 1.2 and 1.3 | Procedure, sample of complaint files |
| Final responses within eight weeks with Financial Ombudsman Service referral rights | DISP 1.6 | Complaints log with dates |
| Root causes analysed and fixed | DISP 1.3.3R | Root-cause MI and actions closed |
| Complaints return filed twice a year within 30 business days | DISP 1.10 | RegData submission receipts (FCA) |
6. Client money
| Check | Rule | Evidence |
|---|---|---|
| Risk transfer agreements in place and recorded for each insurer | CASS 5.2 | Signed agreements and register |
| Client money held in a properly designated trust account | CASS 5.3 and 5.5 | Bank acknowledgement letters |
| Reconciliations performed and differences resolved promptly | CASS 5.5 | Reconciliation pack and breaks log |
| Annual client money audit report obtained and filed | SUP 3.10 | Auditor's report and submission receipt |
7. Financial crime
| Check | Rule | Evidence |
|---|---|---|
| Systems and controls to counter financial crime, proportionate to risk | SYSC 6.1.1R | Financial crime risk assessment |
| Anti-bribery procedures covering producing brokers, introducers and gifts | SYSC 6.1.1R; Bribery Act 2010 s.7 | Due diligence files, gifts and hospitality register |
| Sanctions screening of customers, insureds and claims payees | Sanctions and Anti-Money Laundering Act 2018 | Screening records and escalation log |
| Insurance fraud and ghost broking monitored | SYSC 6.1.1R | Fraud MI and cases |
8. People and reporting
| Check | Rule | Evidence |
|---|---|---|
| Senior managers approved; prescribed responsibilities allocated | SUP 10C; SYSC 24 | Responsibilities map and statements of responsibilities |
| Certified staff assessed as fit and proper every year | SYSC 27 | Certification records |
| Conduct rules training delivered and breaches reported | COCON | Training records and conduct rules log |
| Staff competent for their roles, with training set by role rather than a fixed number of hours | SYSC 28 | Role-based training plan and records (our guide) |
| RMAR filed at least twice a year within 30 working days | SUP 16.12 | RegData receipts (FCA) |
| GI pricing attestation and pricing information report by 31 March, where in scope | ICOBS 6B.2.60R; SUP 16.28 | Signed attestation and evidence pack (FCA) |
| Operational incident reporting ready for 18 March 2027 | PS26/2 | Incident classification procedure (FCA) |
| Changes notified to the FCA on time, including controllers and close links | SUP 11; SUP 15 | Notifications log |
How to use the checklist
Run it as a yearly baseline, then test the higher-risk areas more often through the compliance monitoring plan. For each check, record a rating, the evidence seen and any action with an owner and a date. Report the results to the board with the Consumer Duty outcomes review, so that the two tell one story. Our broker compliance guide explains the requirements behind each heading in more depth, and the UK insurance compliance calendar sets the dates.
Firms that want the checks run for them can use our insurance broker compliance support.
Frequently asked questions
Permissions and resources, sales and disclosure, Consumer Duty and product governance, claims, complaints, client money, financial crime, senior managers and competence, and regulatory reporting. Each check should name the rule and the evidence that proves it is met.
No. PS25/21 removed the prescribed 15-hour minimum from 9 December 2025. Firms must still ensure staff are competent for their roles under SYSC 28 and keep training records.
No. Since 9 December 2025 the review frequency for non-investment insurance must be set by each product's risk of customer harm, recorded with a rationale and shared in the distribution chain on request.
Most sections are reported at least twice a year, based on the firm's accounting reference date, and each return is due within 30 working days.
Yes, on request. ICOBS 4.4.1R requires prompt disclosure of the commission the broker and any associate receive, and ICOBS 4.4.2G says this should include all forms of remuneration, including payments from premium finance providers.
Once a year as a full baseline, with higher-risk areas tested more often through the compliance monitoring plan and reported to the board.
References
- FCA PS25/21: simplifying the insurance rules
- FCA CP26/22: simplifying the insurance rules
- FCA CP26/23: Consumer Duty scope and proportionality
- FCA: retail mediation activities return
- FCA: complaints data items FAQs
- FCA: general insurance pricing attestation
- FCA: general insurance brokers acting for commercial customers
- FCA PS26/2: operational incident and third party reporting
- FCA Handbook
About Regulatory Counsel
Regulatory Counsel provides compliance support for insurance brokers and MGAs: monitoring and file reviews, product governance and fair value, Consumer Duty reporting, client money, training and competence, and regulatory returns. Every enquiry is answered the same business day with a written proposal: contact us.
This article is general information as at 27 October 2026 and is not legal advice.
Definitive guides on this topic
The permanent reference pages this article relates to.