Category: Compliance & AML · Reviewed by Jake Leat, Associate Director · Last reviewed June 2026
The ICOBS chapter requiring firms to disclose, in good time before conclusion of a contract, information about the firm’s identity, status, the nature and basis of any advice, the basis of remuneration, conflicts of interest and complaint handling.
ICOBS 4 sets the pre-contract status disclosure framework for insurance distribution. It requires firms to disclose key information about themselves and the nature of the service before the customer is bound. The disclosure includes whether the firm is acting on behalf of the customer or the insurer, whether advice is being given on a fair and personal analysis basis, and the basis of remuneration.
FCA Handbook, ICOBS 4. Made under FSMA sections 137A and 138, implementing UK retained IDD Articles 17 (information by insurance distributors) and 19 (conflicts of interest and transparency).
The disclosure typically takes the form of a Terms of Business document or Customer Status Disclosure. It must cover: the firm’s name, address, FCA authorisation status with FRN, whether the firm is an insurer or intermediary, the scope of service (e.g. “we offer a personal recommendation on the basis of a fair and personal analysis”), the remuneration basis (commission, fee, or mixed), any conflicts of interest, applicable law, complaint handling and the right to refer to FOS where eligible, and FSCS protection where applicable.
For commercial customers, the disclosure can be calibrated — but the duty to disclose remuneration applies regardless of customer type for IDD-regulated business. The FCA’s PS23/5 on commission disclosure for commercial customers reinforces this. For pure protection products, additional details on the long-term insurance regulatory framework may be relevant.
Apex provides a Terms of Business document to each new client, disclosing FCA authorisation under FRN 724952, the basis on which the firm acts, the commission and / or fee basis of remuneration, the complaint handling process, FOS eligibility considerations and the firm’s data protection notice signposting.
FCA Handbook, ICOBS 4. Financial Services and Markets Act 2000, sections 137A and 138. UK retained Insurance Distribution Directive (Directive (EU) 2016/97), Articles 17 and 19. FCA Policy Statement PS23/5.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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