Product Oversight and Governance (POG)

Category: Compliance & AML · Reviewed by Taylor Watts, Broker · New Business · Last reviewed June 2026

Definition

Product Oversight and Governance (POG) is the set of rules and standards under which insurance manufacturers and distributors design, approve, distribute and review insurance products. POG covers the product approval process, target market identification, product testing, distribution strategy, ongoing monitoring, and feedback from distributors back to manufacturers.

Legal / Regulatory basis

FCA Handbook, PROD 4 (and ICOBS 6A for elements directly within ICOBS). UK retained IDD Article 25 and UK retained Commission Delegated Regulation (EU) 2017/2358 (POG for insurance products).

How it works in practice

Manufacturer duties under PROD 4 include: maintaining a product approval process; identifying a target market and a negative target market; performing product testing (qualitatively or quantitatively where appropriate); identifying and managing relevant risks; choosing a distribution strategy appropriate for the target market; providing distributor information; conducting regular product reviews. Distributor duties include: understanding the manufacturer’s target market; ensuring the distribution strategy is consistent with the target market; periodically reviewing distribution to ensure outcomes remain aligned; providing feedback to the manufacturer. The Consumer Duty overlays POG with the fair-value and outcomes-focused requirements.

Common variations

For commercial insurance products outside the Consumer Duty scope, PROD 4 still applies as the implementation of IDD Article 25. Co-manufacturers share manufacturer duties on a documented basis. Where Apex acts purely as a distributor it carries the distributor duties; where Apex acts as a (co-)manufacturer (e.g. for a scheme product), it carries manufacturer duties.

Example

At each annual review, Apex obtains updated target market and fair value statements from each manufacturer carrier, reviews the firm’s own distribution outcomes (customer mix vs. target market, complaint rates, claims experience, retention), and provides feedback to the manufacturer. Persistent issues lead to product withdrawal or escalation.

See also

• ICOBS 6 — Product information
• Target market assessment
• Fair value assessment
• Distribution chain responsibilities
• Manufacturer vs distributor duties
• PRIN 2A — The Consumer Duty
• Insurance Distribution Directive (IDD)

References

FCA Handbook, PROD 4 and ICOBS 6A. UK retained Insurance Distribution Directive (Directive (EU) 2016/97), Article 25. UK retained Commission Delegated Regulation (EU) 2017/2358.

Last reviewed

By Apex Insurance Brokers on 2026-06-11.

This entry is part of the Apex Insurance Wiki. Last reviewed by Apex Insurance Brokers on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.