Aipedia: Insurance brokers

AI-written marketing and financial promotions for brokers

Aipedia, by the Apex broking team · Last reviewed 2026-10-27

Marketing copy written by AI is still the broker's financial promotion and must be clear, fair and not misleading under ICOBS 2.2.2R. A generative tool that overstates cover can mislead customers and create complaints, regulatory issues and intellectual property risk.

Part of: AI in insurance brokers

In short

Brokers use generative AI to write website pages, social media posts, email campaigns and product summaries. The output is often fluent but generic, and it can overstate cover, omit key limitations or copy phrasing from other sources. ICOBS 2.2.2R requires communications, including financial promotions, to be clear, fair and not misleading, and the Consumer Duty consumer understanding outcome applies to retail customers. Misleading marketing is mainly a regulatory risk, while copied content raises intellectual property issues that sit between PI and cyber or media cover.

How brokers use AI for marketing

Broker marketing teams, and often busy account executives, use generative AI to draft product pages, blog posts, trade-specific landing pages, social media posts and email newsletters. AI is also used to write short product summaries and comparison tables on quote pages, and to translate or simplify policy information for customers.

The tools are good at producing readable text quickly. They are not good at knowing what a particular policy covers, and they tend to produce confident, positive descriptions unless told otherwise.

For retail products, the Consumer Duty raises the bar further. Marketing is part of how customers come to understand a product, and the FCA expects firms to test whether communications actually work for the customers who receive them. Generic AI copy written for a broad audience may not meet that standard for a specific target market; see Consumer Duty for insurance brokers and the four Consumer Duty outcomes.

The duties that apply

ICOBS 2.2.2R: when a firm communicates information, including a financial promotion, to a customer, it must ensure it is clear, fair and not misleading. ICOBS 2.2 also requires marketing communications in insurance distribution to be clearly identifiable as such.
Consumer Duty: the consumer understanding outcome applies to retail customers, and PRIN 2A.2.1R requires firms to act in good faith.
Principle 7: listed in the FCA AI Update, it requires firms to pay due regard to clients' information needs and communicate in a clear, fair and not misleading way.
Records: keep approved versions of promotions and evidence of review.

BIBA's AI guide notes that AI is not "a panacea for serving customers", which applies to marketing as much as service.

What can go wrong

Illustrative: a broker asks a generative AI tool to write a landing page for its tradesperson insurance scheme. The page says the scheme "covers your tools wherever they are, day or night". The actual wording excludes theft from unattended vehicles overnight unless the tools are in a locked toolbox. Customers who rely on the page and suffer an overnight van theft complain that they were misled, and some go to the Financial Ombudsman Service.

A second risk is intellectual property. AI-generated copy, images or guides can reproduce material from other sources. A competitor or publisher may allege infringement. See AI-generated content and IP infringement for how cyber and PI policies treat that overlap.

How PI usually responds

Misleading marketing affecting many customers is usually a regulatory and complaints problem. Regulatory fines are often uninsurable or excluded, while Ombudsman awards fall within the MIPRU 3.2.4R minimum terms, so individual complaints may be covered depending on the wording. Intellectual property claims arising from marketing content may sit under a PI policy's IP or media extension, a cyber policy, or neither, depending on the wordings. Brokers should not assume either policy covers AI-generated content without checking.

Practical controls

Brief AI tools with the actual policy wording and key limitations, not just the product name.
Have every financial promotion approved by someone who knows the product and the rules.
Check that AI copy states material limitations and exclusions with appropriate prominence.
Run AI text and images through originality checks and avoid prompts that imitate competitors.
Keep approved versions with dates and the approver's name.
Review old AI-generated pages when products or wordings change.

How Apex helps

Apex arranges PI for insurance brokers. We can check whether your PI or cyber cover includes any media or IP extension that would respond to a claim about AI-generated marketing.

Sources

Frequently asked

Do financial promotion rules apply to AI-written content?

Yes. ICOBS 2.2.2R applies to communications, including financial promotions, whoever or whatever wrote them. The firm must make sure the content is clear, fair and not misleading before it is published.

Can a broker be liable for AI-generated images or text that copy someone else's work?

It can. If marketing content reproduces protected material, the rights holder may bring a claim against the firm that published it. Whether insurance responds depends on any IP or media cover in the PI or cyber policy.

Should AI-written promotions go through the normal sign-off process?

Yes. AI makes drafting faster, but the approval step remains the firm's main control. A person who understands the product and the rules should approve the final version and the record should be kept.

Does misleading AI marketing affect broker E&O cover?

Individual complaints and Ombudsman awards may be covered depending on the wording, but fines are often excluded. A pattern of misleading promotions may also be relevant information to disclose when renewing your own PI.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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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 how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.