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

Applicants should submit an application form and additional documentation with all relevant documents. We will not consider an application complete if there are any outstanding documents.

The application pack must consist of:

  • Application Fee;
  • Application Form;
  • Financial Projections for the next 3 years;
    • Stress Test on Financial Projections;
    • Profit and Loss account;
    • Balance Sheet;
  • Regulated Individual Form (for each Regulated Individual);
  • Non-Executive Director Form (for each non-executive director);
  • Controller Form (for each Controller);
  • Business Plan;
  • Conduct Risk Framework;
  • Risk methodology and/or threat assessment matrix; 
  • Mapping assessment of how the application meets the relevant legislative threshold requirements (i.e. statutory/regulatory criteria for licensing under relevant Act); and
  • Any other document the applicant considers the GFSC should take into consideration as part of the application.

Please request cloud access from the Authorisation team in order to submit the Application Pack via E-mail to authorisations@gfsc.gi with the following information in the subject field: ‘Name of Regulated Firm/Applicant – Application’. Paper copies are not required unless indicated by the Authorisation 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.  

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.

The business plan should comprehensively set out:

  • How the firm proposes to conduct activities;
  • How the firm will ensure that consumers are protected and their suitable needs are met;
  • An assessment of the firm’s main risks and how these are to be mitigated;
  • The resources that are to be made available and the systems that the applicant intends to employ;
  • How clients will be sourced;
  • How records will be maintained;
  • How, and by whom, any significant decisions will be made;
  • Compliance with AML requirements (if applicable);
  • What reporting lines the firm will establish;
  • Business Continuity Plan; and
  • If the applicant forms part of a larger group, the applicant should provide details of the activities of the group and a description of its structure.

The GFSC will be seeking evidence that the firm has considered, documented and implemented the risk, compliance and operational issues associated with the proposed activities.

Applicants should also ensure that the business plan is coherent with the firm's risk appetite and capacity.