FCA authorised · FRN 7249520117 325 0027Quote & buy →
Reviewed by Apex Insurance Brokers · Last reviewed 2026-06-23
An FCA-authorised general insurance broker arranging PI for a UK firm:
The broker's regulatory duties under FCA principles (ICOBS, IDD, Consumer Duty for retail/SME): act in good faith, provide fair presentation support, disclose remuneration, manage conflicts.
One practical difference between the two channels is what the FCA requires to be disclosed about how the sale is made.
| Disclosure | What ICOBS requires | Why it matters to a buyer |
|---|---|---|
| Status | A firm must tell the customer its name and address and whether it is an insurance intermediary or an insurance undertaking | Tells you whether you are dealing with a broker or with the insurer itself |
| Basis of service | An insurance intermediary must say whether it gives a personal recommendation on the basis of a fair and personal analysis, or is contractually obliged to place exclusively with one or more insurers, or does neither — in which case it must name the insurers it does business with | Distinguishes whole-of-market advice from a panel or single-insurer arrangement |
| Advice statement | Before an initial contract with a consumer a firm must state whether it is giving a personal recommendation not on a fair and personal analysis, other advice on a fair analysis of the market, other advice not on a fair analysis, or just information | Tells you whether what you received is advice at all |
| Size of the analysis | Where a firm gives advice on the basis of a fair analysis of the market, the analysis must cover a sufficiently large number of contracts available on the market | A short panel may not satisfy the fair analysis test |
| Complaints | The firm must explain how to complain to it and to the Financial Ombudsman Service, or the alternative route where FOS does not apply | Sets out your escalation route if the placement goes wrong |
Source: FCA Handbook ICOBS 4.1, including ICOBS 4.1.6R and ICOBS 4.1.7R, and the guidance on fair analysis referring to ICOBS 5.3.3R (handbook.fca.org.uk).
Buying direct means:
Common direct providers for UK PI include Hiscox (small business), AXA, Aviva (some product lines), and a handful of specialist mutuals (VDS for vets).
For these firms, direct often offers a simple online quote, no fee, and an immediately-binding policy. The direct insurer's product is well-tested and the firm just plugs into it.
For firms in these situations, the broker's market access and wording expertise are usually worth materially more than any modest premium saving from going direct.
A common assumption: brokers add commission, so direct is cheaper. The reality is more nuanced.
FCA ICOBS 4.1 requires an insurance intermediary to tell you whether it gives a personal recommendation on the basis of a fair and personal analysis, or places exclusively with named insurers, before you buy.
For most commercial PI placements, the broker fee is the small incremental cost. The market access and wording advice usually pay for it many times over across a 5-year window.
This is where the broker-vs-direct distinction matters most.
The broker is on the policyholder's side. The insurer's claims team works for the insurer. Both are governed by the policy wording and FCA rules, but the broker's role is to help the policyholder navigate the process.
For commercial customers (most firms buying PI):
For larger commercial customers, FOS does not apply. Dispute resolution is via the courts. The broker's value here is largely in marshaling the policyholder's position pre-litigation.
Apex Insurance Brokers Limited acts as broker for UK professional services firms across PI, cyber, commercial combined and run-off. FCA firm reference number 724952. We disclose remuneration basis on engagement and explain when broker involvement is materially better than direct (most commercial cases) and when direct is fine (very small, very simple firms).
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email info@apexinsurancebrokers.co.uk, or request a quotation.
Get a quoteICOBS 4.1 requires disclosure of the firm’s name and address, whether it is an insurance intermediary or an insurance undertaking, whether it gives a personal recommendation on the basis of a fair and personal analysis, whether it is contractually obliged to place exclusively with named insurers, and how to complain to the firm and to the Financial Ombudsman Service.
