Applying for a permission

Insurance & Reinsurance Intermediaries 

About

The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What Insurance and Reinsurance Intermediaries are and what this regulated activity would allow you to do
  • Authorisation Process
  • Capital Requirements
  • Additional Information

What are Insurance and Reinsurance Intermediaries and what would this regulated activity allow you to do?

Insurance and Reinsurance Mediation refers to any activity involving the advising on, proposing or undertaking of preparatory work for entering into insurance contracts, including administration and performance of insurance contracts. Insurance intermediaries are brokers or agents who represent consumers in insurance transactions.

Two types of regulated activity you can apply for:

  • General/Non-Life Business.
  • Life Business.

General/Non-Life Business

This encompasses a wide variety of insurance lines of business that include but is not limited to:

  • Motor Insurance
  • Household insurance
  • Marine Insurance
  • Commercial Insurance
  • Liability insurance

Life Business

This term is used for all forms of insurance cover that is linked to a person's life. These include:

  • Term Insurance: protects dependants in the event of a death during a specified short period of time. The sum assured is payable only if death occurs within the defined period.
  • Whole Life: protection for loved ones to ensure they receive a sum of money upon a death.
  • Endowment: protection with an element of savings because it not only pays dependants upon a death but it also pays a sum of money if the person lives to a certain age.
  • Unit Linked: An investment policy with an element of insurance protection.

Application Process

Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.

Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.

The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.

Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’.  Paper copies are not required unless indicated by the team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

Stage 1 - Business Model, Capital & Key Individuals

The following is to be submitted for Stage 1: 

On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.

When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.  

Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime

The following is to be submitted for Stage 2: 

  • Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
  • Documentation and information including, but not limited to:
    • Corporate Governance and control
    • Business Continuity Management Plan
    • IT infrastructure, Cyber and systems including outsourcing arrangements
    • Operational & Outsourcing Risk including material outsourcing arrangements
    • Systems controls & Risk Management
    • Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
    • Risk Methodology and framework policy documents
    • Risk Register & controls
    • Disaster Recovery Plan 
    • Updated business plan, if required.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.

When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.

Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures

The following is to be submitted for Stage 3: 

  • Stage 3 of the General Comprehensive Business Plan;
  • Documentation and information including, but not limited to:
    • Non-financial resources
    • Compliance structure
    • Conduct of Business (Full Conduct Risk Framework documents)
    • Detail of KPIs
    • Consumer Duty compliance (as applicable)
    • Operational Resilience compliance (as applicable)
    • Remuneration Policy 
    • Conflict of Interest Policy
    • Conflict of Interest Register
    • Liquidity/solvency policies 
    • Internal Audit Plan 
    • Complaints Handling Policy 
    • Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable 
    • Audit, accounting, and banking arrangements 
    • Professional Indemnity Insurance 
    • Contracts with parties to whom material operational functions are outsourced 
    • Completed and signed Regulated Individual Forms and Non-Executive Director Forms
    • Mobilisation Plan (if applicable).

When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation.  

Additional Services

Regulated Firms that are already authorised by the GFSC may apply to extend their permission to provide additional financial or professional services. If you are seeking authorisation for additional services, please contact the Authorisation team in order for us to determine what documents are required for submission.

The below sets out an overview of the expected information requested:

  • Application Fee (if applicable);
  • Revised Business Plan;
  • Financial Projections for the next 3 years, clearly identifying the impact of the additional business:
    • Profit and Loss account
    • Balance Sheet
    • Stress Test on Financial Projections
  • Regulated Individual Form (for any new individual carrying out a Regulated Individual function);
  • Controller Form (for any new Controllers within the structure); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

The Regulated Firm should consider the following:

  • What new services/permissions it requires;
  • The type of new business/activity;
  • Where the business will be sourced;
  • Resources to deal with the additional business;
  • The impact of the additional business on its capital requirements; and
  • What changes are being effected to its systems and controls.

Capital Requirements

An Insurance or Reinsurance Intermediary is required to hold an initial and ongoing capital of:

  • €19,510; or 
  • 4% of the sum of annual premiums received or as projected at application, whichever is the greater.
  • Subject to the above, the GFSC expects firms to hold a minimum level of financial resources equivalent to 3 months’ worth of operating expenses (or as projected at application).

Regulated Firms authorised to provide multiple services may be required to hold the aggregate of the capital required for each authorisation prior to conducting the proposed activity, and on an ongoing basis. In these cases, we will consider the level of capital. We advise that applicants discuss the level of capital with us ahead of the application.

Additional Information

There are prescribed minimum requirements established under the Act regarding the premises, capital, solvency, management, staff and resources that have to be attained in order to be licenced. Insurance and Reinsurance Intermediaries are required to have on a permanent basis;

  • Professional Indemnity Insurance covering the whole territory of the Union, guaranteeing against liability arising from professional negligence, for at least €1,300,380 (or sterling equivalent) applying to each claim and in aggregate €1,924,560 (or sterling equivalent) per year for all claims.
  • Ensuring that money paid by the policyholder to the Intermediary is treated as having already been paid to the Insurance Company, whereas money paid by the Insurance Company to the Intermediary is not treated as having been paid to the policyholder until the customer actually receives it.
  • Ensuring that policyholders’ money is only transferred via strictly segregated client accounts and that these accounts shall not be used to reimburse other creditors in the event of bankruptcy.
  • Ensuring they have adequate mechanisms for receiving and dealing with Complaints.
  • Life Insurance and Life Reinsurance Intermediaries must comply with the GFSC’s Anti money laundering Guidance Notes.