Foundations
Part of Business insurance foundations for small firms in England
Business insurance market entry checklist for publishers
A business insurance market entry checklist for publishers and intermediaries: scope, regulatory permissions, evidence, controls and launch sign-off.
This business insurance market entry checklist is for an organisation planning an insurance information, comparison, introduction or distribution service aimed at small businesses in England. The regulatory perimeter depends on what the service actually does, not the wording chosen for its homepage. Obtain specialist advice before launch.
What to take away
- Permissions and contractual authority must be effective before launch, not after.
- Every comparison needs a check date, product version and published inclusion method.
- Test the service with a small group before any wider launch.
- A go, conditional go or no-go decision should be recorded before any wider launch.
Define the proposition
- Name the legal entity, trading name, owners and responsible managers.
- Specify whether the service publishes information, collects leads, compares, introduces, arranges, administers or advises.
- Define customer types, sectors, company sizes and England relevance.
- List every policy class and excluded risk.
- Map insurers, brokers, managing agents, technology providers and data recipients.
- State who handles quotations, money, documents, renewals, changes, complaints and claims.
Do not combine regulated and unregulated activities in one vague description. Draw the customer journey from first question to policy issue and later service.
Customer journey: question to policy
- First question
- Publish information or collect leads
- Compare or introduce
- Arrange or administer
- Advise
- Policy issue
- Later service
Resolve permissions and status
- Obtain legal perimeter analysis for every activity and communication, against the perimeter set by the Financial Services and Markets Act 2000 and the Regulated Activities Order.
- Identify whether the firm needs credit broking or insurance distribution permissions, or will act as an appointed representative of an authorised principal or as a directly authorised firm.
- Match the exact entity and permissions on the FCA Register.
- Check which activities the service performs, including advising on insurance contracts, arranging deals in insurance contracts, making arrangements with a view to insurance transactions, and assisting in the administration and performance of insurance contracts; map each to the required permission.
- For direct authorisation, complete the FCA firm's authorisation application through Connect and check the current application requirements before submission.
- If acting as an appointed representative, agree the scope and responsibilities with the authorised principal in writing before launch.
- Check the FCA's professional indemnity insurance requirements in MIPRU 3 and put the required cover in place before carrying on insurance distribution.
- Agree written terms of business with insurers, brokers and other relevant distribution partners, setting out authority, responsibilities, remuneration and customer hand-offs.
- Check the FCA's client assets rules (CASS) for client money, the financial promotion rules in COBS 4, and complaint handling under DISP.
- Approve all status wording and required disclosures under ICOBS 4.
- Prevent launch until permissions and contractual authority are effective.
The FCA's authorisation guide for general insurance intermediaries covers intermediaries, London market firms and price-comparison websites. It expects applicants to relate permissions to their business model, explain customer, distribution and client-money arrangements, and satisfy the FCA's threshold conditions. Applications are submitted through the FCA's Connect system.
Permissions and status checks
- Legal perimeter analysis for every activity
- Principal, appointed representative or directly authorised
- Match entity and permissions on FCA Register
- Client money, financial promotions, complaints
- Approve status wording and disclosures
- No launch until permissions effective
After authorisation, FCA fees include an annual periodic fee and levies, with the amounts set out in the FCA's fees manual (FEES). Check the current manual for applicable application and periodic fees, and confirm published processing information rather than assuming a fee or authorisation timeline. The Financial Ombudsman Service levy and the Financial Services Compensation Scheme levy may also apply. Firms with insurance distribution permissions usually submit the Retail Mediation Activities Return (RMAR). They must also report complaints, notify the FCA of significant changes, and meet Senior Managers and Certification Regime responsibilities where senior management functions apply.
Build the evidence model
- Obtain current wordings, summaries, limits, exclusions, conditions and insurer identity.
- Define how prices are requested and when an indicative value becomes a quotation.
- Publish the provider panel and inclusion method.
- Record fees, commissions, lead payments, sponsored position and ownership ties.
- Give every comparison a check date and product version.
- Keep rejected products and reasons rather than displaying only winners.
For example, an illustrative comparison record could show a check date of 1 April 2025 and product version 2.3. The inclusion method could be 'invited panel, ranked by price after disclosed fees'. Rejected products could be 'flood-excluded risk' and 'turnover outside appetite', each with a recorded reason.
For commercial customers, FCA Handbook ICOBS 4 contains applicable information about firm status, service scope and remuneration. The relevant provisions are ICOBS 4.1 to 4.4 on information about the firm, the service and remuneration, and PRIN 2A where the consumer duty applies.
Evidence model requirements
- Current wordings, limits, exclusions, insurer identity
- When indicative value becomes quotation
- Publish provider panel and inclusion method
- Record fees, commissions, lead payments, ownership ties
- Check date and product version for comparisons
- Keep rejected products and reasons
Protect customers and information
- Ask clear questions that match underwriting and eligibility evidence.
- Allow correction before submission and preserve what the customer approved.
- Minimise personal and commercially sensitive data.
- Check whether the organisation must register with the Information Commissioner's Office (ICO) and pay the data protection fee; record any applicable exemption.
- Apply the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018 to personal data handling.
- Assess cookies and electronic marketing against the Privacy and Electronic Communications Regulations 2003 (PECR), including any consent requirements.
- Restrict access, test suppliers, encrypt transfers and define retention.
- Provide accessible human help for unusual risks or unclear answers.
- Test a declined quote, wrong classification, data incident and failed handoff.
Operate accountable publishing
- Name writers, fact-checkers and regulated reviewers where required.
- Link claims to first-party or official sources.
- Separate editorial ranking from commercial payment.
- Check marketing claims and the clear identification of advertorials against the CAP Code and Advertising Standards Authority (ASA) requirements.
- Maintain corrections, complaints and product-withdrawal procedures.
- Recheck volatile facts on publication day and at renewal cycles.
- Hold content that lacks a verified provider record or clear scope.
Prove the service before a wider launch
- Test with a small, defined group whose risks match the intended audience.
- Compare captured answers with the information received by the regulated partner.
- Sample journeys for omissions, misleading rankings and inaccessible wording.
- Measure corrections, abandoned handoffs, document delivery and complaint themes.
- Give reviewers authority to stop a campaign, provider or product journey.
- Set numerical thresholds for investigation, although they should not replace case review.
Keep test records long enough to reconstruct what a user saw, submitted and received. Remove or minimise data that is no longer required under the documented retention approach. Before changing the journey, assess whether the amendment changes the regulated activity, target customer, product panel, commercial incentive or information passed to another party.
A strong market opportunity does not cure missing permission, ambiguous responsibility or unreliable product evidence.
Launch decision
The sign-off roles are compliance, operations, security and the commercial owner. A go decision requires effective permissions and contractual authority, a published evidence model and a tested customer journey. A conditional go requires named remedial actions with owners and dates. A no-go decision applies where permissions, evidence or customer outcomes are not adequate.
Common questions
What determines whether the service falls inside the regulatory perimeter?
The article advises obtaining specialist advice before launch and drawing the customer journey from first question to policy issue and later service.
What should be recorded about how comparisons are ranked and paid for?
The article says to publish the provider panel and inclusion method, and to record fees, commissions, lead payments, sponsored position and ownership ties. Every comparison should carry a check date and product version, and rejected products should be kept with reasons.
How should a firm test the service before a wider launch?
Test with a small, defined group whose risks match the intended audience. Compare captured answers with what the regulated partner received, sample journeys for omissions and misleading rankings, and measure corrections, abandoned handoffs, document delivery and complaint themes.
