PI requirements · ICAEW · As at September 2026

Accountants’ PI insurance requirements: the ICAEW minimum

ICAEW’s Professional Indemnity Insurance Regulations, in force since 1 September 2024, set the minimum a member firm must hold by gross fee income. Here is the current requirement, the excess and run-off rules, and how to judge whether it is enough.

Part of: PI insurance requirements by professional body

What ICAEW requires

ICAEW’s Professional Indemnity Insurance Regulations, in force since 1 September 2024, set the minimum cover a member firm must hold, by gross fee income (GFI):

• GFI of £800,000 or more (Reg 3.2): at least £2 million for any one claim and in the aggregate.
• GFI below £800,000 (Reg 3.3): 2.5 times gross fee income, subject to a minimum floor of £250,000, for any one claim and in the aggregate.

The formula reaches £2 million at £800,000 of fee income (2.5 × £800,000 = £2 million), where the flat £2 million rule takes over. Firms doing probate or estate-administration work must hold at least £500,000 for any one claim (Reg 3.5), and firms doing insurance-distribution work must also meet the FCA/IDD-prescribed limits (Reg 3.4). The maximum aggregate excess must not exceed the higher of £3,000 or 3% of gross fee income (Reg 3.7). Firms with GFI over £50 million may self-insure but must take all reasonable steps to meet claims (Reg 3.8).

Each claim vs aggregate: why the basis matters

Two policies can both say ‘£2 million’ and protect you very differently. The difference is the basis of the limit.

• Each and every claim (or ‘any one claim’). The full limit is available for every separate claim, however many you face in a policy year. A firm on a £1 million each-and-every policy is covered for three £1 million claims in the same year.
• In the aggregate. The limit is the most the insurer will pay in total across the whole year, added together. On a £1 million aggregate policy, those same three claims exhaust the cover after the first.

ICAEW sets its limit for any one claim and in the aggregate, so the cover must satisfy both tests — a policy that met the figure only per claim, or only in aggregate, would not comply.

This is why a firm holding £1 million in the aggregate can still fail a requirement written as ‘£1 million for any one claim’ — the number matches but the basis does not. Read the basis of your requirement, not just the figure, and check whether defence costs sit outside the limit or erode it.

Run-off: cover after you stop

Professional indemnity is written on a claims-made basis: the policy that answers a claim is the one in force when the claim is made or notified, not the one you held when you did the work. So when you stop trading, the cover does not follow your old work automatically — a claim can still arrive years later, and there is no live policy to meet it unless you have bought run-off cover.

On an individual leaving practice (Reg 2.7) or a firm ceasing (Reg 2.8), the firm must maintain compliant cover for at least two years, then take all reasonable steps to maintain cover for a further four years — six years in total.

Run-off matters most on retirement, closure, a merger or a change of legal structure. A retroactive date that reaches back over all your past work is what keeps that earlier work covered; if you change insurer or broker, protecting that date is the point to watch.

Is the minimum enough?

A regulatory minimum is a floor, not a recommendation. ICAEW sets the least cover you may hold and still practise; it does not promise the figure is enough for your work. A single claim on a large contract, a valuation, a set of accounts or a piece of advice can run well past the minimum once the loss and the other side’s legal costs are added.

The 2024 change lifted the floor for the smallest firms to £250,000 and set a flat £2 million for larger ones, but a single negligent set of accounts or tax opinion can exceed £2 million once the client’s loss and costs are counted — the regulations are a minimum, not a ceiling.

Judge the limit against your own exposure: the size of the contracts you sign, the value of the work you touch, what your clients and their lenders require in writing, and your claims history. Our minimum-limit calculator and our guide to how much professional indemnity insurance you need walk through that. A broker’s job is to place the right limit, not just the lowest one you are allowed to buy.

How Apex helps you meet it

Apex Insurance Brokers is an independent insurance broker established in 2009 and based in Bristol, owned entirely by its directors and directly authorised by the FCA since 2016, placing professional indemnity insurance for accountants across the UK. It is one of the longest-established independently owned professional indemnity specialists in the UK, and it is not for sale: we have declined approaches to buy the firm. We are not tied to any single insurer or professional-body scheme, we do not run our own policy or underwriting, and we have no placement quotas. We have access to over 30 markets, including Lloyd’s syndicates via wholesale, and we usually return three or four competing quotes set out so you can compare them like for like. Every client has a named broker — the same person from first quote to renewal — and every claim notification gets director-level attention rather than a call-centre queue.

• Owned by its directors, not for sale. No consolidator, no private-equity owner, no external shareholders — and we have declined approaches to buy the firm. Read the Apex Independence Charter.
• Independent, not tied. No single-insurer scheme, no in-house policy, no placement quotas — the recommendation is the one that fits, not the one we are paid to push.
• Over 30 markets, including Lloyd’s. Specialist UK PI insurers and Lloyd’s syndicates via wholesale, so a risk that one underwriter dislikes can still be placed properly with another.
• Usually three or four competing quotes, laid out side by side — limit, excess, retroactive date, exclusions and premium — with a plain-language note on the trade-offs.
• The stay-put letter. If your existing cover is right, we say so in writing, free and without obligation. How the stay-put letter works.
• A named broker all year. The person who places your cover is the person who picks up the phone at renewal, on a mid-term change, or when a letter of claim lands.
• Director-level attention on claims. We help you notify circumstances early and in the right form, stay involved once the insurer’s panel solicitors are appointed, and tell you plainly where you stand.
• Directly authorised by the FCA since 2016, not an appointed representative trading under someone else’s permissions.

Related pages

• PI insurance requirements by professional body
• Accountants’ PI insurance: the 2026 guide
• What accountants’ PI insurance costs
• ACCA firms’ PI requirements
• AAT members’ PI requirements
• Get a comparison quote

Frequently asked

Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about professional indemnity insurance requirements, not advice on your individual circumstances, and it does not set, guarantee or replace the rules of any professional body or regulator. Every requirement shown is the position as at September 2026 against the source linked beside it; these requirements change, so confirm the current rule with the body itself before you rely on it. Apex does not set or enforce any professional body’s minimum.