PI requirements · FCA MIPRU 3.2 · As at September 2026

Insurance and mortgage brokers’ PI requirements: FCA MIPRU

An FCA-authorised insurance or mortgage intermediary must hold PI insurance meeting MIPRU 3.2. Here is the current euro-denominated minimum, how it converts to sterling, the equivalents for investment firms, and how to judge whether it is enough.

Part of: PI insurance requirements by professional body

In short

An FCA-authorised insurance intermediary must hold professional indemnity insurance meeting MIPRU 3.2. The minimum limit is €1,300,380 for a single claim and, in the aggregate, the greater of €1,924,560 or 10% of annual income, capped at £30 million. Mortgage and home-finance intermediaries must hold €460,000 for each claim and €750,000 a year in the aggregate. The limits are set in euros and convert to sterling at the exchange rate when the policy is arranged, so there is no fixed pound figure. This is the position as at September 2026; verify the current requirement with the FCA, as the rules change. Apex is an independent, director-owned broker that checks your cover meets MIPRU and returns competing quotes.

What the FCA requires

An FCA-authorised insurance intermediary must take out and maintain professional indemnity insurance at least equal to the limits in MIPRU 3.2. For insurance-distribution firms (MIPRU 3.2.7R), the minimum limits are:

€1,300,380 for a single claim; and
in the aggregate, the greater of €1,924,560 or 10% of annual income, this amount capped at £30 million.

A mortgage or home-finance intermediary (regulated under the Mortgage Credit Directive) must hold €460,000 for each individual claim and €750,000 a year in the aggregate.

The limits are set in euros in the FCA Handbook, and the sterling equivalent floats with the exchange rate — a firm converts at the rate prevailing when the policy is arranged or renewed, so there is no fixed pound figure in the rule. Higher own-funds or capital requirements apply where a firm takes an excess above the set thresholds.

Equivalent limits apply to personal investment firms under IPRU-INV 13.1: the same €1,300,380 single and €1,924,560 aggregate figures, plus sterling income floors — at least £500,000 for a single claim where relevant income is up to £3 million, and at least £650,000 single and £1 million aggregate above £3 million.

Rule and date. FCA Handbook, MIPRU 3.2.7R (insurance intermediaries: €1,300,380 single / greater of €1,924,560 or 10% of income aggregate, capped at £30m) and MIPRU 3.2 (home finance: €460,000 / €750,000); IPRU-INV 13.1 (personal investment firms, with £500k/£650k/£1m income floors). As at September 2026 — verify the current requirement with the FCA (FCA Handbook, MIPRU 3.2), as these requirements change.

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.

The FCA sets both a single-claim and an aggregate minimum, and the aggregate for insurance intermediaries is the greater of a fixed euro figure or 10% of income — so a larger firm’s aggregate requirement rises with its income, up to the £30 million cap.

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.

MIPRU 3.2 does not set a fixed run-off period the way the legal and accountancy bodies do. Cover is claims-made, so an intermediary winding down should still arrange run-off to meet claims about past advice; confirm what your permissions and any principal require.

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. The FCA 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 euro minimums are a regulatory floor; a firm advising on large commercial risks, or holding client money, may need more, and the aggregate requirement itself rises with income. The figures also move with the euro exchange rate, so the sterling cost of meeting them changes year to year.

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 insurance and mortgage intermediaries 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.

Frequently asked

What is the minimum PI insurance for an FCA-authorised insurance broker?

Under MIPRU 3.2.7R the minimum is €1,300,380 for a single claim and, in the aggregate, the greater of €1,924,560 or 10% of annual income, capped at £30 million. The limits are set in euros. This is the position as at September 2026; confirm the current requirement with the FCA.

Why are the limits in euros, and what do they cost in pounds?

The figures come from the EU Insurance Distribution Directive and are written in euros in the FCA Handbook. There is no fixed pound figure: you convert at the exchange rate prevailing when the policy is arranged or renewed, so the sterling equivalent moves year to year. A broker works out the current pound figure your cover has to meet.

Is the MIPRU limit per claim or in aggregate?

Both. MIPRU sets a single-claim minimum of €1,300,380 and a separate aggregate minimum — the greater of €1,924,560 or 10% of your annual income, capped at £30 million. So the aggregate requirement rises with income for larger firms, and your policy must satisfy the single-claim and aggregate tests together.

What is the minimum for a mortgage or home-finance broker?

A mortgage or home-finance intermediary regulated under the Mortgage Credit Directive must hold €460,000 for each individual claim and €750,000 a year in the aggregate. Like the insurance-intermediary figures these are euro amounts that convert to sterling at the prevailing rate. Confirm the current requirement with the FCA.

Do these rules cover financial advisers and investment firms?

Separate but equivalent rules apply. Personal investment firms fall under IPRU-INV 13.1, which sets the same €1,300,380 single and €1,924,560 aggregate figures, plus sterling income floors: at least £500,000 for a single claim up to £3 million of relevant income, and at least £650,000 single and £1 million aggregate above £3 million.

Do brokers need run-off cover?

MIPRU 3.2 does not set a fixed run-off period as the legal and accountancy bodies do. But professional indemnity is claims-made, so an intermediary winding down should still arrange run-off to answer claims about past advice, and check what its permissions and any principal firm require. A broker helps you put that in place.

Is the MIPRU minimum enough?

It is a floor. A firm advising on large commercial risks, or holding client money, may need more, and the aggregate requirement already rises with income. Because the euro figures also move with the exchange rate, the sterling cost of meeting them changes year to year. Our calculator and how-much guide help you size the right limit.

Check your cover meets the minimum

Send your current schedule and renewal terms. A named Apex broker checks the limit, basis and run-off against your body’s requirement and returns competing quotes set out so you can compare them like for like. 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 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.