Is Your PI Cover Fit for Purpose?

Is Your PI Cover Fit for Purpose?

A 30-point self-assessment for UK professional services firms.

How this works

Read each question. Tick Yes, No, or Unsure. Each question carries a short “what good looks like” note and a “what to do if your answer was No or Unsure” note. At the end there is a scoring rubric. The scoring rubric is a tool for prompting the right conversations inside the firm, not a substitute for a policy review.

Nothing in this document is regulated advice. Nothing in it constitutes a recommendation about a specific product or insurer.

Part one — scope and structure

1. Can you name the legal entity, in full, that is the named insured on your policy?

A good answer: yes, and it matches the entity that holds the firm’s regulatory authorisation, signs engagement letters and bills clients. If you have a holding company, a trading company, and one or more service companies, you have checked which are insured.

If your answer was No or Unsure: pull the policy schedule. Match the named insured against your latest filed accounts and your professional body register entry. Mismatch is one of the most common avoidable gaps.

1. Are all subsidiaries, trading names, joint ventures and consortia that carry on regulated or fee-earning work either named on the policy or covered by a “subsidiary” definition that extends to them?

A good answer: yes, and you have a written list, dated, updated within the last twelve months.

If your answer was No or Unsure: a subsidiary or trading name that is not within the policy definition is uninsured. Ask your broker to confirm in writing which entities sit inside cover.

1. Have you compared the activities described in your policy schedule against the activities the firm has actually carried on in the last twelve months?

A good answer: yes. Any new service line, advisory work, training, software or hosted service, and any work for a new client type has been flagged and disclosed.

If your answer was No or Unsure: do this before the next renewal. Activity drift is normal in growing firms; uninsured activity drift is avoidable.

1. Have you mapped the geographic jurisdictions in which the firm has accepted instructions or carried out work in the last twelve months?

A good answer: yes. The jurisdiction clause and the territorial clause in your policy both extend to those jurisdictions.

If your answer was No or Unsure: territorial and jurisdiction limits are two separate clauses. Both matter. US, Canadian and certain commonwealth jurisdictions are commonly excluded by default.

1. Have you confirmed that the retroactive date on your policy precedes the earliest date the firm carried out work that could still give rise to a claim?

A good answer: yes, the retroactive date is at or before the firm’s incorporation, or at or before the date the firm acquired the relevant book of business.

If your answer was No or Unsure: a retroactive date that is later than your earliest exposure creates a blind spot for that earlier work. This is one of the highest-impact, lowest-visibility issues in UK PI.

Part two — limit, excess and structure

1. Has the limit of indemnity been tested against the firm’s largest single matter and against the firm’s aggregate exposure in the worst plausible scenario in the last twelve months?

A good answer: yes, and the test is documented. The result was discussed at partner level.

If your answer was No or Unsure: limits set in year one and rolled forward indefinitely are common and usually no longer fit the firm. Set a documented review at least every two years.

1. Do you know whether your limit is “each and every claim” or “in the aggregate”, and have you decided that the basis chosen is appropriate?

A good answer: yes. You can explain the difference and the partners are comfortable with the basis you have.

If your answer was No or Unsure: aggregated wording is usually cheaper but can be exhausted by a series of related claims. Each-and-every wording can be materially better for firms with a high client count.

1. Do you know whether defence costs sit inside or outside the limit?

A good answer: yes, and the partners are aware. If costs are “in addition” to the limit, that is recorded; if costs erode the limit, the firm has considered whether the limit is high enough to absorb both.

If your answer was No or Unsure: defence costs on a contested claim can be a multi-six-figure number. If they erode the limit, the indemnity available to the claimant is reduced.

1. Has the excess been set at a level the firm can absorb without operational disruption?

A good answer: yes. The excess is recorded, and finance has a current view on the firm’s ability to fund it from working capital or facilities.

If your answer was No or Unsure: an excess set against last year’s balance sheet may not match this year’s. Review at every renewal.

1. Where the firm has more than one professional discipline or risk profile, has the programme been structured to reflect that? For example, separate towers or specific endorsements for the higher-risk disciplines.

A good answer: yes, the structure has been intentionally chosen and the rationale recorded.

If your answer was No or Unsure: a single policy covering a wide range of activities can leave high-risk activities under-covered and low-risk activities over-paying. Discuss alternatives at the next renewal.

Part three — disclosure and claims

1. Did the proposal form or market submission at the last renewal accurately reflect the firm’s activities, fee income, structure and claims history?

A good answer: yes, and the firm retains the signed submission with the policy file.

If your answer was No or Unsure: the duty of fair presentation under the Insurance Act 2015 is not satisfied by a tick of the box. Material inaccuracies can give the insurer remedies up to and including avoidance.

1. Was a documented circumstance review carried out with every principal and senior fee-earner in the 60 days before the last renewal?

A good answer: yes, signed and dated, with each individual confirming awareness or absence of circumstance.

If your answer was No or Unsure: an undisclosed circumstance, even one that did not crystallise during the year, can affect the response of the new policy if a claim later arises out of it.

1. Are open complaints, regulatory letters, fee disputes and litigation logged in one place that the renewal owner can access?

A good answer: yes. There is a single log. The renewal owner does not have to gather this information from four mailboxes each year.

If your answer was No or Unsure: build the log this quarter. It supports renewal disclosure and protects the firm in any later coverage dispute.

1. Does the firm have a written internal protocol for what to do when a matter that could give rise to a claim is identified?

A good answer: yes. It names the person to call, the file to open, the matter to preserve, and the timeline for broker notification.

If your answer was No or Unsure: in the absence of a protocol, the first response is usually delayed and rarely consistent. Build one and brief the whole firm.

1. Does the firm know the policy notification address and the agreed format for circumstance notification?

A good answer: yes, both are in the protocol.

If your answer was No or Unsure: notification by casual email to a personal address is rarely a valid notification.

Part four — practice and people

1. Have new partners, new senior hires and senior departures in the last twelve months been notified to the insurer and reflected in the cover?

A good answer: yes. Prior-acts cover for incoming partners has been considered; run-off arrangements for outgoing partners with high-exposure books have been arranged where appropriate.

If your answer was No or Unsure: this is one of the most common gaps in growing firms.

1. Have material acquisitions, mergers, or asset purchases in the last twelve months been notified and reflected in the cover?

A good answer: yes. Prior-acts cover for the acquired book is in place or has been explicitly declined with the partners’ knowledge.

If your answer was No or Unsure: liabilities acquired with the book do not automatically come with cover. Ask before assuming.

1. Are all consultants, sub-contractors and seconded staff who do client-facing work either covered under the firm’s policy or required to carry their own with appropriate limits?

A good answer: yes. There is a documented vetting process and a register of evidence.

If your answer was No or Unsure: a sub-contractor’s error can become the firm’s claim. Establish a written position on each.

1. Does the firm hold cyber and crime cover separately from PI, and has the interaction between the three been mapped?

A good answer: yes. The firm has considered whether a social engineering loss, a ransomware-driven service failure, or a regulatory investigation would fall under PI, cyber, crime, or none of the above.

If your answer was No or Unsure: PI is not a substitute for cyber, and vice versa. The interaction matters most at the point of claim.

1. Does the firm hold management liability cover (D&O, EPL, entity defence) at a level the partners understand?

A good answer: yes. The partners can describe in plain English what is covered.

If your answer was No or Unsure: many PI policies do not respond to claims against partners personally for non-professional acts. Management liability fills a different gap.

Part five — regulatory and ongoing fitness

1. Have you confirmed in the last twelve months that the cover meets the minimum requirements of every professional body the firm is regulated by?

A good answer: yes. Minimum limit, minimum wording terms, run-off requirements and any specific endorsements required have all been checked against the current rules.

If your answer was No or Unsure: minimum requirements move. Even a firm that has not changed its programme can fall out of compliance if the body has changed its rules.

1. Has the firm’s data protection position been considered in the design of the cover?

A good answer: yes. The firm has thought about whether claims arising from a personal data breach, regulator fines (where insurable), and notification costs fall within PI, cyber or both.

If your answer was No or Unsure: the regulator does not divide the world by insurance line, and your cover should be designed accordingly.

1. Has the firm’s vulnerable client position been considered? Both as a duty owed by the firm and as a feature of any claim against the firm?

A good answer: yes. The firm understands the Consumer Duty position where it applies and has considered how a claim by a vulnerable client would be handled.

If your answer was No or Unsure: claims involving vulnerable clients can be handled badly by firms that have not thought about the issue in advance.

1. Does the firm review the policy wording itself, not just the schedule, at least every two years?

A good answer: yes. The wording has been read by someone at the firm in the last 24 months.

If your answer was No or Unsure: wording changes slowly but materially. A reading every two years catches the drift.

1. Does the firm understand how its premium is calculated and what would move it up or down at the next renewal?

A good answer: yes. The firm has a view on the drivers of its rating and on the levers it can pull to improve them.

If your answer was No or Unsure: ask your broker to walk you through the rating in plain language at the next renewal meeting.

Part six — the broker relationship

1. Do you know, in writing, how your broker is remunerated for placing your PI?

A good answer: yes. You have a recent written disclosure showing commission, fee, profit share or combination.

If your answer was No or Unsure: ask. UK brokers must disclose the nature and basis of their remuneration on request.

1. Has your broker provided a written market report on the last renewal that explains which insurers were approached, which declined, which quoted, and why the recommended option was recommended?

A good answer: yes, and it is on file.

If your answer was No or Unsure: ask for one at the next renewal. A market report is the firm’s audit trail of the placement decision.

1. Has the broker tested the market in the last three years against an alternative insurer or alternative structure?

A good answer: yes, and the result of the test is documented.

If your answer was No or Unsure: there is no rule that says a firm must change broker or insurer. There is value in knowing what the alternative looked like.

1. Does the firm have a written claims advocacy expectation from the broker?

A good answer: yes. The firm knows whether the broker will lead claims advocacy on its behalf, what is included and what is not.

If your answer was No or Unsure: at the point of a contested claim, the firm wants to know in advance what its broker will and will not do.

1. Has the firm checked the broker’s regulatory standing on the FCA register in the last twelve months?

A good answer: yes. The firm has confirmed the broker is authorised, the permissions are current and there are no published notices that warrant a conversation.

If your answer was No or Unsure: register.fca.org.uk is public and free. Most firms do not look. Looking takes two minutes.

Scoring

Count your Yes answers.

26 to 30: your programme has been thoughtfully designed and maintained. Use the next renewal to refresh the items that scored less than Yes, rather than to redesign.

20 to 25: there are gaps. None of them are necessarily urgent, but two or three are likely to matter. Prioritise the items in Part three (disclosure and claims) and Part five (regulatory and ongoing fitness) at the next renewal.

13 to 19: significant gaps. The cover may still respond in most foreseeable claims, but the firm is exposed to surprises. A structured review with your broker, with this self-assessment as the starting point, is worth scheduling.

12 or below: the programme has not had a serious look in some time. This does not mean the firm is uninsured. It does mean the firm does not have a current basis for being confident in the cover. Schedule a full review.

Optional: send me my score

If you would like an Apex broker to read your completed self-assessment and discuss the items that scored less than Yes, send the completed PDF to info@apexinsurancebrokers.co.uk with the subject line “PI self-assessment”. There is no charge for the conversation and no commitment to switch.

Apex Insurance Brokers Ltd. Registered office: c/o Westcan, 5 Anglo Office Park, Bristol BS15 1NT. Trading address: QCS, 53 Queen Charlotte Street, Bristol BS1 4HQ. Registered in England and Wales, Companies House number 07014570. Authorised and regulated by the Financial Conduct Authority, firm reference number 724952. Verify our registration at register.fca.org.uk.

Speak to Apex about your cover — 0117 325 0027 or info@apexinsurancebrokers.co.uk

Last reviewed: May 2026