For many insurers and MGAs, distribution drives growth. Brokers, price comparison websites, Appointed Representatives and delegated authority arrangements let firms scale, reach specialist markets and diversify revenue. They also sit squarely within the FCA’s supervisory focus, and they are now one of the most material strategic, regulatory and commercial risks facing Boards.
The FCA’s position is clear: firms cannot contract out of their regulatory responsibilities. Consumer Duty has raised the evidential bar further. Boards are now expected to show that oversight delivers good customer outcomes across the distribution chain, not just that a framework exists. Our new white paper looks at what effective, proportionate oversight looks like in practice. It draws on the latest regulatory developments, including the FCA’s 2026 Insurance Regulatory Priorities, its July 2026 outcomes-monitoring findings, PS25/21 and the Consumer Duty proposals in CP26/23. It also sets out how strong oversight can protect revenue and support sustainable growth.
What you will find in the white paper
- How accountability follows the role a firm actually performs, not the structure of the distribution chain, and what that means for manufacturers, MGAs, brokers, principals and outsourced providers
- Practical guidance across the oversight lifecycle: governance, onboarding and due diligence, ongoing monitoring, product governance and value, remuneration and conflicts, complaints and root cause analysis, and terminating arrangements
- The commercial case for oversight: protecting revenue, improving the quality of business and knowing which relationships create value
- The Square 4 framework: seven dimensions of effective oversight, the evidence Boards should expect to see and the warning signs that warrant challenge
- A practical Board challenge to test whether your firm could evidence effective oversight today
Who should read this?
This white paper is for Boards, SMFs, Non-Executive Directors and senior executives at insurers, MGAs and intermediaries who are responsible for distribution strategy, product governance and conduct risk.
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