Compliance Support for MGAs
Compliance support for managing general agents: PROD 4 roles and lead firm arrangements, delegated authority and claims oversight, broker oversight, Consumer Duty evidence and board reporting.
Compliance support for an MGA covers the obligations that come from writing business on an insurer's behalf: PROD 4 manufacturer roles and lead firm arrangements, oversight of brokers and claims administrators, Consumer Duty outcomes evidence, capacity provider audits and FCA returns, run on a monitoring plan and reported to the board.
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Tell us the business, the products and where your compliance framework stands. Every enquiry is answered the same business day, with a written proposal setting out the scope, the team and the timing.
Your enquiry
What we do
An MGA sits between the insurers that give it capacity and the brokers that bring it business, and the FCA expects it to evidence both relationships. Under PROD 4 an MGA often acts as a co-manufacturer. Since 9 December 2025 an insurer or managing agent can act as sole lead manufacturer, but an MGA cannot, so it must still be able to show its own role and share information with the lead firm on request.
We map the MGA's role on every product, check the written arrangements that allocate responsibilities, and build the evidence each capacity provider will test at audit: product reviews at a recorded frequency, fair value inputs, broker oversight, claims and complaints MI, and Consumer Duty outcomes. Our [PROD 4 guide for MGAs](/insights/prod-4-compliance-mgas-2026) explains the roles.
The FCA began a review of outsourcers and delegated authority models in 2026, with findings expected in early 2027. We prepare MGAs for it: oversight of third-party claims administrators, remuneration conflicts, and MI that shows customer outcomes across the chain. Our [rule change tracker](/insights/fca-insurance-rule-changes-tracker-2026) follows every related change.
Role mapping
The MGA's PROD 4 role, delegated authorities and responsibilities on every product and binder.
Oversight framework
Broker and claims administrator oversight, MI and escalation, set against capacity provider requirements.
Monitor and evidence
Product reviews, file reviews, outcomes MI and audit preparation on a fixed plan.
Report
Board and capacity provider reporting that shows outcomes, findings and actions.
What's Included
PROD 4 role and lead firm review
Product-by-product role mapping and review of the written arrangements with the lead firm.
Delegated authority oversight
Binder compliance, claims administrator oversight and audit evidence for capacity providers.
Broker and distribution oversight
Due diligence, distribution strategy checks and MI on the brokers that place business.
Consumer Duty evidence
Outcomes MI by product and customer group, and the yearly board review.
Capacity provider audit preparation
Evidence packs and remediation tracking ahead of insurer and Lloyd's audits.
Returns and rule change
RMAR and complaints returns, and each rule change turned into specific updates.
Who does what in an MGA chain
A typical allocation where an insurer acts as lead manufacturer. Written arrangements should confirm the actual split.
| Obligation | Insurer (lead firm) | MGA | Broker |
|---|---|---|---|
| Product approval and fair value | Owns, with full liability | Provides information and data | Provides distribution information |
| Product review frequency | Sets and records | Shares data on request | Sets for its distribution arrangements |
| Underwriting within the binder | Sets authority and audits | Underwrites within authority | Places business |
| Claims handling | Oversees | Handles or oversees a claims administrator, where delegated | Supports its client |
| Distribution oversight | Oversees the MGA | Oversees brokers | Follows the distribution strategy |
| Consumer Duty outcomes | Reviews across the product | Reviews its own role | Reviews its own role |
Who this service is for
Firm types
- - MGAs writing on behalf of insurers
- - Lloyd's coverholders
- - Start-up MGAs building their first framework
- - MGAs using third-party claims administrators
Situations & Triggers
- - Capacity provider audit approaching
- - New binder or new capacity provider
- - Preparing for the FCA's delegated authority review
- - Growth through new products or distribution partners
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
PROD 4 Compliance for MGAs in 2026: What the FCA Expects
PROD 4 compliance for an MGA starts with its actual role in each product. Manufacturer status brings product approval, target market, fair value and review duties, and the rules changed in December 2025 and June 2026.
MGA Compliance in 2026: FCA Requirements for UK MGAs
An MGA compliance framework should follow the business the firm actually runs, because MGA is a commercial label, not an FCA category. Permissions, PROD 4, Consumer Duty, delegated authority, claims and monitoring should work as one system.
Delegated Authority Compliance in 2026: A Practical Guide for MGAs and Insurance Firms
Delegated authority lets insurers place underwriting, claims and administration with MGAs and other firms. The FCA is reviewing delegated and outsourced claims oversight in 2026, with findings expected in early 2027.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a compliance expertFrequently asked questions
No. Since 9 December 2025 only an insurer or a Lloyd's managing agent with significant involvement in the product can act as sole lead firm. An MGA can rely on the lead firm but must co-operate and share information.
PROD 4 role mapping, review of lead firm arrangements, delegated authority and claims administrator oversight, broker oversight, Consumer Duty outcomes evidence, capacity provider audit preparation, returns and board reporting.
The FCA began a review of outsourcers and delegated authority models in 2026, covering oversight and remuneration, with findings expected in early 2027.
At a frequency set by the product's risk of customer harm, recorded with a rationale, since the 12-month minimum was removed on 9 December 2025. Where an insurer is lead firm, the MGA shares data for the lead firm's review.
Yes. We help coverholders build the oversight, MI and evidence that managing agents test at audit, alongside their FCA obligations.
No. We are an advisory firm. Your senior managers keep their responsibilities, and we provide the monitoring, evidence and support they need.
Yes. We build the first-year framework: role mapping, oversight, monitoring plan, MI and board reporting, ready for capacity provider due diligence.
As a fixed monthly retainer scoped to the MGA's size, binders and level of support. The scope and the fee are set out in writing before work begins.