IUA Circular 064/25
IUA Guidance on Commissions (including SMB)
Date: 22 September 2025
Interest Groups: IUA member contacts, underwriting and claims committees and interests.
Subject: Circulation of IUA Guidance, Commentary and a KC Opinion relating to commissions (including Subscription Market Brokerage).
Contact: Tom Hughes Director of Underwriting +44 (0)78 2533 4264
Downloads accompanying this circular:
This circular and the associated guidance and commentary do not opine on the payment of commissions, however named or structured, or the quantum of such commissions. These matters are for commercial and contractual parties to negotiate and are beyond the scope of any trade association operations. This circular and the accompanying guidance are designed solely for the purpose of promoting transparency and disclosure of commission arrangements, and to reiterate the UK regulatory rules currently in place.
By way of background, in late 2024 and through early 2025, the IUA Board considered the ongoing challenges surrounding acquisition costs and the transparency of Subscription Market Brokerage (SMB). In addition to the increasing prevalence of SMB and similar arrangements, recent litigation and FCA intervention regarding motor finance premiums have prompted reconsideration of these matters from a regulatory compliance and governance perspective.
With the agreement of the IUA Board, we have drafted a short guidance note on commission arrangements (downloadable above) and some explanatory comments (downloadable above). We have also contributed financially to a King’s Counsel (KC) opinion commissioned by the LMA on this matter, accessible here to IUA Members (login required), and highlight key points from the opinion in the commentary.
If you have any questions or comments, please contact Tom Hughes using the details shown above.