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ICOBS 2.1 Client categorisation



1Different provisions in this sourcebook may apply depending on the type of person with whom a firm is dealing:

  1. (1)

    A policyholder includes anyone who, upon the occurrence of the contingency insured against, is entitled to make a claim directly to the insurance undertaking.

  2. (2)

    Only a policyholder or a prospective policyholder who makes the arrangements preparatory to him concluding a contract of insurance (directly or through an agent) is a customer. In this sourcebook, customers are either consumers or commercial customers.

  3. (3)

    A consumer is any natural person who is acting for purposes which are outside his trade or profession.

  4. (4)

    A commercial customer is a customer who is not a consumer.

Customer to be treated as consumer when status uncertain


If it is not clear in a particular case whether a customer is a consumer or a commercial customer, a firm must treat the customer as a consumer.

Customer covered in both a private and business capacity


If a customer is acting in the capacity of both a consumer and a commercial customer in relation to a particular contract of insurance, the customer is a commercial customer.

Customer classification examples


In practice, private individuals may act in a number of capacities. The following table sets out a number of examples of how an individual acting in certain capacities should, in the FSA's view, be categorised.

Customer classification examples



Personal representatives, including executors, unless they are acting in a professional capacity, for example, a solicitor acting as executor.


Private individuals acting in personal or other family circumstances, for example, as trustee of a family trust.


Trustee of a trust such as a housing or NHS trust.

Commercial customer

Member of the governing body of a club or other unincorporated association such as a trade body and a student union.

Commercial customer

Pension trustee.

Commercial customer

Person taking out a policy covering property bought under a buy-to-let mortgage.

Commercial customer

Partner in a partnership when taking out insurance for purposes related to his profession.

Commercial customer