17. March 2026
FCA Consultation Paper CP26/8: Limited Amendments Affecting Insurance Firms
Regulatory Briefing Note No. 1/26 - March 2026
Audience: Insurance Brokers and Managing General Agents (‘MGAs’)
Overview
The Financial Conduct Authority (‘FCA’) has published Consultation Paper CP26/8, Quarterly Consultation Paper No. 51, proposing a range of technical amendments across the FCA Handbook.
While most proposals relate to other sectors, one targeted amendment affects the FCA’s Insurance: Conduct of Business Sourcebook (‘ICOBS’).
The proposed change is technical in nature and low impact, primarily aligning FCA guidance with new UK consumer protection legislation.
Proposed ICOBS Amendment
The FCA proposes updating ICOBS 2.2.4G, which provides guidance on pricing claims in financial promotions.
The amendment would clarify that firms should ensure pricing claims in insurance promotions comply not only with existing consumer protection legislation but also with the Digital Markets, Competition and Consumers Act 2024 (‘DMCCA’).
This change reflects the evolving UK consumer protection framework and ensures that FCA guidance remains consistent with the broader legislative environment governing marketing practices.
What this means for Brokers and MGAs
The proposal does not introduce new conduct obligations, but it reinforces expectations that firms ensure pricing claims are accurate, substantiated and not misleading.
Firms should review:
- Marketing and advertising content referencing price leadership or value claims.
- Aggregator and digital marketing messaging.
- Governance and approval processes for financial promotions.
Practical implications
For most insurance intermediaries, the impact is expected to be minimal. However, firms should ensure that compliance frameworks for financial promotions take account of the expanded consumer protection regime under the DMCCA.
This is particularly relevant where firms use marketing claims such as:
- “Lowest price”
- “Best value”
- “Cheapest cover”
These claims must be capable of substantiation and consistent with both FCA rules and wider consumer protection law.
Consultation timeline
- The FCA is accepting feedback on the proposed amendments until 13 April 2026.
- Final rules are expected later in 2026 following the consultation process.
Next steps
Insurance brokers and MGAs should:
- Monitor the outcome of the consultation.
- Ensure marketing governance frameworks reflect broader consumer protection expectations.
- Confirm that pricing claims in financial promotions remain clear, fair and not misleading.
The small print...
This document has been prepared by AJG Reg Solutions for the purpose of contributing to regulatory discussion and consultation. The views expressed in this response represent the professional opinions of AJG Reg Solutions based on our regulatory expertise and experience supporting firms operating in the financial services sector.
Unless explicitly stated otherwise, the views set out in this document do not represent the views of any individual client of AJG Reg Solutions. Any examples or references to market practice are provided for illustrative purposes only and should not be interpreted as referring to any specific firm.
This response is provided in good faith for the purposes of regulatory engagement and policy development. It should not be relied upon as legal advice, and readers should seek appropriate professional advice in relation to their specific circumstances.
AJG Reg Solutions accepts no responsibility or liability for any loss arising from reliance on the contents of this document. Information contained in this response may be shared publicly by the relevant authority as part of its consultation process unless otherwise indicated.