Reviewed by Matthew Bartlett, Director · Last reviewed 8 July 2026
If a client has raised a formal complaint about the suitability of advice, if a claims-management company has written on behalf of a former client, if the Financial Ombudsman Service has notified you of a case, or if you have identified a past recommendation that could develop into a claim, this entry sets out how a UK IFA should think about the next 24 to 48 hours. It covers notification under the claims-made wording, why timing is critical, what the FCA and FOS expect in parallel, and what your broker does at this point. Read it once, then pick up the phone.
IFAs' PI cover is written on a claims-made basis. The wording responds to claims and notified circumstances arising during the period of insurance, not to matters that arose during it but were never told to the insurer. The Insurance Act 2015 sits underneath the wording: section 3 imposes the duty of fair presentation at inception, renewal and any material variation; section 13A gives the insured a remedy where an insurer has breached the implied term to pay claims within a reasonable time. Late notification is one of the largest single technical reasons claims fall over at coverage stage. Notifying a circumstance does not commit you to admitting anything — it preserves the year's cover you have already paid for.
A claim under an IFA's PI wording does not need to be a court proceeding. It can be a written complaint under DISP 1, an email or letter from a CMC, a subject access request that reads as fact-finding for a claim, a FOS notification, or a note in a file that a reasonable director of the firm would read as something that might turn into a claim. The wording standard is that a fact, matter, event or circumstance which may reasonably be expected to give rise to a claim must be notified. The test is objective. Once the compliance officer, a director or an SMF holder has identified it, the practical clock has started.
The FCA regulates advised investment business under COBS. COBS 9 (suitability) is where the majority of claims land: the record of the suitability assessment, the client's objectives and capacity for loss, and the demonstration that a personal recommendation was appropriate. DISP sets the complaint-handling rules for the firm, including the acknowledgement and eight-week timelines and the requirement to refer eligible complainants to the Financial Ombudsman Service. The Financial Ombudsman Service has statutory jurisdiction under Part XVI of FSMA 2000 and can award binding compensation up to its published award limit. The Consumer Duty (PRIN 2A) has raised the bar on foreseeable-harm avoidance and product-and-service outcomes; a complaint that engages Consumer Duty considerations will typically be scrutinised in both the FOS and the FCA supervisory lens. Where the matter involves defined-benefit pension transfers, the FCA's supervisory approach following BSPS remains highly active.
Do not respond to the client, the CMC or the FOS on substance until you have notified your broker. Preserve the fact-find, suitability report, meeting notes, recorded calls, email trail and file review notes. Do not annotate or "tidy" a client file after the event. Do not admit liability, offer a goodwill payment that reads as an admission, or float a settlement figure in correspondence. Notify your broker straightaway; the broker handles the notification to the insurer in the form the wording requires and manages what happens next. If a FOS deadline is running, tell the broker in the first conversation — that changes the sequence. The DISP acknowledgement and eight-week response obligations continue in parallel and must be met.
A named broker who has run IFA notifications before will take the summary from you, prepare and submit the notification to the insurer in the form the wording requires, protect your position on scope and late-notification questions, and manage the appointment of defence solicitors from the insurer's approved panel. From there the broker deals with reservation of rights letters, the reserve conversation, coverage disputes around DB transfer advice or advised-versus-execution-only questions, and aggregation issues where a systemic advice pattern is being treated as one claim. Apex is a broker, not an insurer or a defence firm; the broker handles the notification and manages the process with the insurer's appointed defence panel. This is the technical work where broker experience matters most.
Not because Apex clients never have claims. Advised investment business carries long-tail exposure by design, and the FOS jurisdiction reaches deep into legacy files. Apex clients renew because when a matter arose, the notification was made properly, the year's cover attached, and the firm reached the next renewal in a position to place terms on the merits rather than under a cloud.
Notification urgent?
If a matter has just arisen, call now. Late notification is one of the largest single reasons claims get declined. A named broker will pick up the phone and start the notification with you.