Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
Insurance broker PI (often known in the trade as broker E&O, for errors and omissions) is priced by an underwriter reading a submission against the FCA's minimum PI rules for insurance intermediaries. There is no shelf price. The rate on income, the treatment of different distribution models (retail, wholesale, delegated authority, Lloyd's-facing), the practice's claims and complaints history, and the limits and excesses chosen all combine to produce the premium. This page sets out what actually drives the number for insurance broking firms and how Apex Insurance Brokers approaches a broker PI submission.
Turnover is the anchor. Underwriters rate on gross commission and fee income, and the rate itself moves with the distribution profile. A retail personal lines broker sits differently from a commercial broker, which sits differently again from a wholesale broker or a broker with delegated underwriting authority from insurers. Firms with Lloyd's-facing business, coverholder authority, or open market placement in the Lloyd's market have distinct risk profiles.
Product mix matters. Firms placing straightforward household, motor, and small commercial business attract a different rate to firms placing complex professional risks, financial institutions, high-net-worth, or specialty lines. Firms doing significant advisory business (recommending cover, negotiating wording, benchmarking limits) will see that reflected in the presentation. Firms with a scheme business, an affinity book, or a delegated authority arrangement will be underwritten with attention to the specific delegated wording.
Claims and circumstances history is central. Broker E&O claims typically arise from allegations of failure to place adequate cover, failure to warn about a cover gap, failure to notify a claim to an insurer within a policy time-limit, or failure to explain a wording feature. Underwriters read the substance of each notification carefully. The compliance framework, the file discipline, the use of standard demands-and-needs statements and record-keeping under ICOBS, the training and competence framework, and whether the firm is directly authorised or an appointed representative are all factored in.
The FCA's minimum PI requirements for insurance intermediaries are set out in MIPRU 3. The minimum single-claim limit is the higher of a specified euro figure (currently the sterling equivalent of around £1.4 million) or 10% of annual income up to a specified cap. The aggregate limit is the higher of a specified euro figure (currently around £2 million sterling equivalent) or 10% of annual income up to a cap. Firms that hold client money need to check the interaction of PI with the client money rules under CASS 5.
Cover must be on a claims-made basis, must include defence costs, and must be placed with an insurer that meets the FCA's requirements. Appointed representatives (ARs) are covered by the principal firm's PI arrangements; the AR's own PI position is determined by the principal's cover, but ARs remain accountable for their own conduct. Directly authorised firms are responsible for their own arrangements.
Consumer Duty (PRIN 2A) applies to retail intermediation and has changed the shape of underwriters' file-review questions in the same way it has for advisers. ICOBS 2 (client's best interests), ICOBS 4 (information about the firm and the service), ICOBS 5 (demands and needs and IDD statements), and ICOBS 6 (product information) all set conduct standards that PI claims are frequently pleaded against.
MIPRU 4.4 also sets the minimum capital resources requirement (broadly, the higher of £10,000 or 5% of annual income). This is a capital standard, not a PI standard, but insurers will typically ask about it when underwriting broker E&O.
Apex Insurance Brokers is itself an FCA-authorised broker (firm reference number 724952), and we place E&O cover for other FCA-authorised intermediaries. We are a named-broker practice: Matt Bartlett or a named colleague reads every submission personally, drafts the presentation, and negotiates on the firm's behalf. We understand the distinction between retail and wholesale, between directly authorised and appointed representative, and between commission-only and fee-charging models.
Our client retention rate across the book is approximately 95%. We work with sole-trader intermediaries, small brokerages, and mid-sized firms including those with delegated authorities. Our approach is to engage on the actual distribution profile in detail, so that the underwriter sees the risk as it actually is.
Any range published on a web page is a starting point for conversation, not a quote. With that on the record: a small retail intermediary at modest income, straightforward personal lines and small commercial mix, and clean claims, will typically see primary broker E&O premiums in the low thousands of pounds a year. Firms with delegated authority, complex commercial placement, or notified claims should expect materially higher terms.
Mid-sized firms often pay a rate on income in the low to mid single digits of a percent, but the number moves with distribution model, claims history, and the limit purchased. Firms with clean records, straightforward retail models, and no delegated authority exposure should expect the market to compete for them. The specific figure comes out of the underwriter's assessment of the submission, not from a table.
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