FCA Consumer Duty · insurance brokers

Consumer Duty for UK insurance brokers — PRIN 2A, MIPRU 3, and broker's own PI

Reviewed by Matthew Bartlett, Director, Apex Insurance Brokers Limited (FCA FRN 724952) · Published 14 July 2026

The FCA Consumer Duty (PRIN 2A) applies with particular force to general insurance intermediaries under FCA insurance distribution rules, including directly authorised firms and appointed representatives. This page sets out how the four outcomes translate into operational practice for insurance brokers, how the Duty widens the boundary between complaint and PI claim, and the compliance checklist Apex uses when quoting or reviewing PI cover for firms in this sector.

The four outcomes — what they mean for insurance brokers

Products and services

Product-oversight distribution (POG) processes must show the broker is placing cover in the target market. Non-target-market placements must be flagged and justified. Wholesale, sub-broking, and Lloyd's coverholder chains fall inside this.

Price and value

Fair value assessment across the entire distribution chain — not just the broker's slice. Commission-plus-fee stacking must be tested. Renewal pricing benchmarked against market movement, not last year's figure.

Consumer understanding

Demands-and-needs statement issued pre-contract, in plain English. IPID and full policy wording provided. Aggregation, retro-date, and run-off provisions explained in writing where relevant.

Consumer support

Claims service quality assessed as an outcome, not just a process. Complaints handled under DISP — the AR/principal boundary matters here, as the principal firm carries FOS accountability for AR complaints.

Consumer Duty complaint patterns in this sector

Complaints that once fell outside the FCA regulatory perimeter can now generate PRIN 2A findings and, via that route, PI notification. Examples we see for insurance brokers:

Undisclosed commission stacking. Client discovered wholesale-broker commission on top of the retail broker's. Under Consumer Duty this can be challenged as a fair-value and consumer-understanding failure even where ICOBS 4.4 disclosure was technically met.
Renewal auto-repeat pricing. Client renewed at 10% above last year without any market check. Consumer Duty analysis argues the price movement was not tested against value delivered.
Claim-service outcome failure. Insurer's claim handler unresponsive; broker did not escalate. Consumer Duty consumer-support outcome challenged. Complaint upheld against the broker under DISP.

Where the Duty overlaps PI cover

PI wordings for insurance brokers respond to civil liability claims. Consumer Duty enforcement action is regulatory, not civil — but the two intersect at several practical points:

MIPRU 3 broker's own PI cover. Every broker must hold PI to the MIPRU 3.2.7R minimum. Consumer Duty widens what counts as a claim — broker's own PI must respond to the new complaint patterns.
DA vs AR PI accountability. AR firms operate under principal firm authorisation. PI cover for the AR must respond to the principal-firm accountability chain. DA firms carry their own PI without principal fallback.
Wholesale chain and coverholder PI. Multi-broker chains create shared exposure. Confirm which PI policy responds first — retail, wholesale, or coverholder.
Notification of thematic issues. Systemic complaint pattern (renewal pricing, commission disclosure) meets the notification threshold. Notify insurer and, where material, the FCA under SUP 15.

Consumer Duty compliance checklist for insurance brokers

Use this as a self-assessment; it maps to what a specialist PI insurer will ask at renewal.

✓MIPRU 4.4 capital position verified against 5% of annual income or £10k minimum
✓MIPRU 3.2.7R broker's own PI cover documented and up to date
✓Fair-value assessment covers the entire distribution chain, not just this firm
✓Product-oversight distribution (POG) records held for every product placed
✓Renewal pricing benchmarked against market movement, documented
✓Commission and any fee disclosed pre-contract, ICOBS 4.4 disclosure on request for commercial customers
✓AR/principal-firm boundary explicit in every AR PI wording
✓Annual Consumer Duty board report on file — SMF16 (Compliance Oversight) sign-off

Professional indemnity

What might your PI premium look like?

A guideline range built from the premiums insurers have actually quoted on risks we handle. Pick your profession and enter a few details — it updates instantly.

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Annual fee income — gross, last 12 months

Limit of indemnity

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Guideline range — this is not a quote

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How these figures are produced

This guide is built from Apex's own market data: the premiums insurers have actually quoted and charged on professional indemnity risks we have handled. Each night that data is aggregated into anonymised rate bands by profession, fee income and limit of indemnity. No client information is published — a band only appears where it contains at least five separate records, and unusually high premiums are excluded so a single atypical risk cannot distort the guide.

The range shown spans the typical spread of recent market outcomes for similar risks. Individual quotes can fall outside it in either direction. Figures exclude insurance premium tax at 12%.

This calculator is not a quote and is not an offer of insurance or advice. Your actual premium depends on full underwriting of your business, including your activities, claims record and insurer appetite at the time.