Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
Your firm’s renewal invitation has arrived and the picture is not what you expected. The premium has climbed while the commission book has stayed flat, the wording review did not engage with the change in your appointed-representative arrangements, or the broker never asked about the mid-year change of permission. Insurance brokers changing their own PI broker at renewal is a common exercise; the mechanics are well established but the FCA regulatory backdrop is denser than most other professions. This entry sets out what to expect, what the outgoing broker has to release, and the MIPRU 3, IPRU-INV 13 and appointed-representative points that must be handled correctly in transit.
Watch for observable signals. The renewal premium moved and the underwriting rationale is not on the file. The wording review was a covering paragraph, not a written analysis of the “insured services” definition, the sub-broker or wholesale carve-out, or the personal-lines-only exclusion. The broker did not ask about the change in permission scope, the addition or loss of appointed representatives, the shift between advised and non-advised distribution, or the acquisition of a book of business. The submission went to a single insurer’s facility rather than an open-market panel used to writing broker-PI risk. Terms landed late. Any of these can be a one-off. 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) does not typically apply between two FCA firms in the way it does to a retail principal, but the underlying ICOBS 2 duty and the FCA principles of business still frame the exercise. A written request for the file is sufficient. You do not owe an explanation for leaving.
The MIPRU 3 rules require an FCA-authorised general insurance intermediary to hold PI cover with minimum limits set on a per-claim and aggregate basis by reference to annual income — the incoming broker needs the current-year income figure and the projected next-year figure to size the limit correctly. Investment-firm brokers within IPRU-INV 13 sit under a parallel framework with its own PII table. Appointed representatives sit under the principal’s PI cover, and any change in the AR count — addition, resignation, permission variation — is a material fact under section 3 of the Insurance Act 2015 and needs disclosure at re-broking. The distribution mix matters: personal lines, commercial, wholesale placing into the Lloyd’s market, sub-broking to overseas producers and delegated authority arrangements all sit differently on an underwriter’s risk sheet. The FCA change-of-control and change-of-permission regimes interact with the renewal position where a firm has moved permission scope in the last year. Consumer Duty as a firm-level obligation and, where applicable, the SM&CR conduct rules also frame the risk picture. Where the firm holds client money under CASS 5, the CASS position and any audit findings belong in the presentation.
Take the mechanics in order.
First, do not cancel the current policy until the new one is bound. A claims-made policy needs an unbroken chain, and MIPRU 3 requires cover in place at all times. Second, give the incoming broker the current wording, schedule, claims record, appointed-representative list, permission profile and CASS position. Third, the fair-presentation duty under section 3 of the Insurance Act 2015 continues at renewal and at every material variation — disclose the AR changes, the permission variations, the distribution mix and any pending FCA correspondence honestly. 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 broking files remain within cover. Sixth, read the definition of “insured services”, the aggregation clause, the CASS carve-in and the AR position on the new wording against the outgoing one. Seventh, cross-check that the limit satisfies the MIPRU 3 formula — both per-claim and aggregate — before you sign the renewal.
A broker doing the work properly on an insurance-broker PI file looks like this. A named broker reads the wording and writes down the analysis. The submission uses the current income figure, the permission scope, the AR arrangement, the distribution mix and the claims record to build the risk picture, and goes to a specialist broker-PI panel on an open-market basis. MIPRU 3 continuity is treated as an operational constraint, not a footnote. Material variations mid-year are handled at the point they happen. When general insurance intermediaries move their PI to Apex Insurance Brokers from another broker, they tell us the difference is that the incoming broker actually understands the regulatory backdrop — MIPRU 3, IPRU-INV 13, CASS 5, appointed representatives — rather than treating the account as a generic professional-services risk. That is the working model, and it is why the retention rate across the professions 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.