Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
The renewal invitation has arrived and the picture is not what you expected. The premium has climbed while the FUM stayed flat, the wording review did not engage with the DB transfer position, or the broker never asked about the shift into intergenerational planning. IFAs and financial planners change broker at renewal for reasons like these and the mechanics are well established. This entry sets out what to expect, what the outgoing broker has to release, and the FCA continuity points that must not slip in the handover.
The signals are observable. The premium moved and the underwriting rationale is not on the file. The wording review was a covering paragraph, not a written analysis of the DB transfer exclusion, the pension advice sub-limit, the SIPP position or the retroactive cover on legacy files. The broker did not ask about the change in permission scope, the arrival of new advisers, the shift between restricted and independent, or the exit from DB transfer advice. The submission went to a single insurer’s facility rather than an open-market panel of specialist IFA underwriters. Terms landed late. Any one of these is explainable. A cluster is a signal.
Under ICOBS 2 information duties and the wider FCA client-service framework, the current broker is required to provide the information you need to make an informed decision at renewal. That means the current wording in full, the schedule, the claims record, the renewal invitation and any change in terms since inception. Consumer Duty (PRIN 2A) applies where the principal is treated as a consumer of the broking service; the “consumer understanding” and “consumer support” outcomes are the practical hooks. A written request for the file is sufficient. You do not owe an explanation for leaving.
FCA COBS 9 sets the suitability framework for personal recommendations and shapes what the PI wording has to answer. Continuity of cover across renewals is essential because the FCA PII rules require adequate cover in place at all times and the policy operates on a claims-made basis. The DB transfer permission, if held, is the single most sensitive line on the underwriting sheet — even historic files remain exposed under the retroactive tail and the FOS ten-year longstop for DB transfer complaints was effectively removed for redress purposes. FOS jurisdiction covers complaints from eligible complainants regardless of broker change, and the FOS award limit is set by the FCA on a rolling basis; the incoming broker needs the limit-of-indemnity discussion sized against it. Restricted versus independent status, any change in adviser count, the volume of pension work versus general investment advice, and the SIPP or offshore-bond exposure all belong on the renewal presentation. Under the Insurance Act 2015 section 3, historic advice files that could still crystallise into complaints are a material fact for fair presentation.
Take the steps in order.
First, do not cancel the current policy until the new one is bound and effective from renewal. A claims-made policy needs an unbroken chain. Second, give the incoming broker access to the current wording, schedule, claims record and any FOS complaint file in play. Third, the fair-presentation duty under section 3 of the Insurance Act 2015 continues at renewal and at every material variation — do not soften a disclosure about DB transfer files, SIPP exposure or a pending FOS complaint. Fourth, any circumstance already notified to the outgoing insurer stays with that insurer; the new policy responds to claims made during its own period. Fifth, confirm the retroactive date on the new policy matches the outgoing inception so historic advice files remain within cover. Sixth, read the DB transfer position, the aggregation clause and the definition of “insured services” on the new wording against the outgoing wording.
A broker doing the work properly on an IFA file looks like this. A named broker reads the wording and writes down the analysis. The submission uses the current permission scope, adviser count, service mix and claims record to build the risk picture, and goes to a specialist IFA panel on an open-market basis. FCA COBS 9 continuity is treated as an operational constraint, not a footnote. Material variations mid-year are handled at the point they happen. When IFAs move to Apex Insurance Brokers from another broker, they say the difference is the same broker on the phone and a wording review that engages with the DB transfer position and the FOS exposure rather than reciting the FCA handbook. That is the working model, and it is why the retention rate on the IFA book runs at 95%.
Renewal at hand?
Send us your current renewal terms and we’ll take a look. A named broker will read every submission and come back within one working day with a proper comparison.