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ICOBS 6.1 General

Responsibilities of insurers and insurance intermediaries


1An insurer is responsible for producing, and an insurance intermediary for providing to a customer, the information required by this chapter and by the distance communication rules (see ICOBS 3.1). However, an insurer is responsible for providing information required on mid-term changes, and an insurance intermediary is responsible for producing price information if it agrees this with an insurer.


If there is no insurance intermediary, the insurer is responsible for producing and providing the information.


An insurer must produce information in good time to enable the insurance intermediary to comply with the rules in this chapter, or promptly on an insurance intermediary's request.


These general rules on the responsibilities of insurers and insurance intermediaries are modified by ICOBS 6 Annex 1 if one of the firms is not based in the United Kingdom, and in certain other situations.

Ensuring customers can make an informed decision


A firm must take reasonable steps to ensure a customer is given appropriate information about a policy in good time and in a comprehensible form so that the customer can make an informed decision about the arrangements proposed.


The appropriate information rule

applies pre-conclusion and post-conclusion, and so includes matters such as mid-term changes and renewals. It also applies to the price of the policy.


3The appropriate information rule applies in the same way to any policy, regardless of whether that policy is sold on its own, in connection with another policy, or in connection with other goods or services.


The level of information required will vary according to matters such as:

  1. (1)

    the knowledge, experience and ability of a typical customer for the policy;

  2. (2)

    the policy terms, including its main benefits, exclusions, limitations, conditions and its duration;

  3. (3)

    the policy's overall complexity;

  4. (4)

    whether the policy is bought in connection with other goods and services;

  5. (5)

    distance communication information requirements (for example, under the distance communication rules less information can be given during certain telephone sales than in a sale made purely by written correspondence (see ICOBS 3.1.14 R)); and

  6. (6)

    whether the same information has been provided to the customer previously and, if so, when.


In determining what is “in good time”, a firm should consider the importance of the information to the customer's decision-making process and the point at which the information may be most useful. Distance communication timing requirements are also relevant (for example, the distance communication rules enable certain information to be provided post-conclusion in telephone and certain other sales (see ICOBS 3.1.14 R and ICOBS 3.1.15 R)).


Cancellation rights do not affect what information it is appropriate to give to a customer in order to enable him to make an informed purchasing decision.


A firm dealing with a consumer may wish to provide information in a policy summary or as a key features document (see ICOBS 6 Annex 2).

Providing evidence of cover


Under Principle 7 a firm should provide evidence of cover promptly after inception of a policy. Firms will need to take into account the type of customer and the effect of other information requirements, for example those under the distance communication rules (ICOBS 3.1).

Group policies


Under Principle 7, a firm that sells a group policy should provide appropriate information to the customer to pass on to other policyholders. It should tell the customer that he should give the information to each policyholder.


  1. (1)

    4This rule applies when a firm proposes to a consumer the renewal of a general insurance contract, which is not a group policy, and which has a duration of 10 months or more.

  2. (2)

    In this rule, ‘renewal’ means carrying forward a policy, at the point of expiry and as a successive or separate operation of the same nature and duration as the policy, with the same insurance intermediary or the same insurer.

  3. (3)

    The firm must provide to the consumer the following information in good time before the renewal:

    1. (a)

      the premium to be paid by the consumer on renewal;

    2. (b)

      in a way that is consistent with the presentation of (a) so that they can be easily compared:

      1. (i)

        except where (ii) applies, the premium for the policy which the firm proposes to renew, as set out at the inception of that policy;

      2. (ii)

        where one or more mid-term changes were made to the policy which the firm proposes to renew, an amount calculated by annualising (or otherwise adjusting as appropriate to the duration of the proposed policy) the premium in effect following the most recent mid-term change, excluding all fees or charges associated with those mid-term changes;

    3. (c)

      a statement alongside (a) and (b) indicating that the consumer:

      1. (i)

        should check that the level of cover offered by the renewal is appropriate for their needs; and

      2. (ii)

        is able, if they so wish, to compare the prices and levels of cover offered by alternative providers.

  4. (4)

    Where the proposed renewal will be the fourth or subsequent renewal the consumer has entered into in respect of the policy, the firm must include the following statement, to appear alongside the matters required by (3)(a), (b) and (c)(i) (but omitting (c)(ii)): “You have been with us a number of years. You may be able to get the insurance cover you want at a better price if you shop around.”

  5. (5)

    The firm must communicate the information in (3) and (4):

    1. (a)

      clearly and accurately;

    2. (b)

      in writing or another durable medium; and

    3. (c)

      in a way that is accessible and which draws the consumer’s attention to it as key information.


4A firm should have regard to the record-keeping obligations referred to in ICOBS 2.4.1G and ensure that it has appropriate systems and controls in place with respect to:

  1. (a)

    the adequacy of its records so it may fulfil its regulatory and statutory obligations; and

  2. (b)

    the sufficiency of its records to enable the FCA to monitor the firm’s compliance with the requirements under the regulatory system.

Price disclosure: connected goods or services

  1. (1)

    If a policy is bought by a consumer in connection with other goods or services a firm must, before conclusion of the contract, disclose its premium separately from any other prices and whether buying the policy is compulsory.

  2. (2)

    In the case of a distance contract, disclosure of whether buying the policy is compulsory may be made in accordance with the timing requirements under the distance communication rules (see ICOBS 3.1.8 R, ICOBS 3.1.14 R and ICOBS 3.1.15 R).

  3. (3)

    2This rule does not apply to policies bought in connection with other goods or services provided as part of a packaged bank account.


5Firms are reminded that when offering a policy as part of a packaged bank account the firm may be subject to the requirements of regulation 13 (payment accounts packaged with another product or service) of the Payment Accounts Regulations.

Exception to the timing rules: distance contracts and voice telephony communications


Where a rule in this chapter requires information to be provided in writing or another durable medium before conclusion of a contract, a firm may instead provide that information in accordance with the distance communication timing requirements (see ICOBS 3.1.14 R and ICOBS 3.1.15 R).