Compliance Officer for Insurance Brokers and MGAs
SMF Capital recruits compliance officers for general insurance brokers and managing general agents: fractional, part-time, interim and permanent. Most of the brokers we speak to don’t need a full-time head of compliance. They need an approved SMF16 who knows ICOBS, insurance product governance, the Consumer Duty, insurance client money and appointed representative oversight, for the right number of days a month. This page explains what the role covers at a broker or MGA, when you also need an MLRO, what it costs and how we find the right person.
Who This Is For
- Commercial and personal lines brokers, from start-ups applying for direct authorisation to established regional brokers
- Brokers leaving a network to become directly authorised
- Managing general agents and coverholders with delegated underwriting authority
- Brokers with their own appointed representatives
- Specialist intermediaries, such as schemes, affinity and niche commercial lines
Larger insurers, Lloyd’s managing agents and their senior teams are covered by our SMF recruitment for insurers. Advice, mortgage and investment firms are covered by compliance officer and MLRO for brokers and advice firms.
The Compliance Officer’s Role at a Broker
Most brokers are Core firms under the Senior Managers and Certification Regime. The compliance officer holds SMF16, Compliance Oversight, and is accountable to the FCA for the firm’s compliance arrangements. At a broker or MGA, that usually means owning:
| Area | What it involves |
|---|---|
| ICOBS | The Insurance Conduct of Business rules: demands and needs, information to customers, suitability where advice is given, claims handling and cancellation |
| Product governance | PROD 4 distributor obligations; for MGAs, often co-manufacturer obligations too, including fair value assessments |
| Consumer Duty | Applies to policyholders within ICOBS scope, including commercial customers, applied proportionately; large risks and reinsurance are excluded |
| Pricing | The general insurance pricing practice rules for home and motor sold to consumers, where relevant |
| Client money | CASS 5: statutory or non-statutory trust, risk transfer, calculations and the annual audit; see CASS 5 explained |
| Training and competence | At least 15 hours of professional training a year for staff involved in insurance distribution, and competence records |
| Appointed representatives | Oversight of any ARs, including annual reviews and the principal’s responsibilities; see appointed representatives explained |
| Complaints and reporting | DISP complaints handling, the RMAR return and regulatory notifications |
| Financial promotions | Approving marketing so it is fair, clear and not misleading; see the compliance officer’s role in financial promotions |
| Monitoring | A risk-based compliance monitoring programme with findings reported to the board; see compliance monitoring explained |
Do You Also Need an MLRO?
Often not. The Money Laundering Regulations apply to insurance intermediaries only when they act in relation to life and other investment-related insurance. A broker that only arranges general insurance is usually outside them, so it doesn’t need an MLRO approved as SMF17. It still needs sanctions screening, fraud controls and the ability to report suspicions under the Proceeds of Crime Act, and someone should own that.
A broker that also arranges life, protection with an investment element or other long-term insurance is likely to be within the regulations and will need an MLRO. At a small firm the same person often holds SMF16 and SMF17. Confirm the position with your regulatory adviser before the application or appointment; see who can be your MLRO or compliance officer.
MGAs Need More
An MGA writing business under delegated authority usually needs a stronger compliance function than a broker of the same size. It is likely to share manufacturer responsibilities under the product governance rules, carry out fair value work with its capacity providers, oversee claims and coverholder arrangements, and deal with Lloyd’s requirements where relevant. Candidates with delegated authority experience are scarcer and command higher rates. For an MGA, test experience of product governance and capacity-provider audits specifically.
How Many Days Does a Broker Need?
| Firm | Typical arrangement |
|---|---|
| Start-up broker during authorisation | 2 to 4 days a month, more in the weeks before submission |
| Small commercial broker, no ARs | 2 to 4 days a month |
| Broker with client money and a growing book | 1 to 2 days a week |
| Broker with several ARs or personal lines volume | 2 to 3 days a week, or a part-time employee |
| MGA or large regional broker | Full-time head of compliance, often with a team |
The right number depends on volumes, complaints, client money, ARs and how much the firm is changing. Our guide to how many days a week a fractional compliance officer needs explains how to estimate it.
What It Costs
Fractional compliance officers for brokers typically charge £650 to £1,000 a day, often as a monthly retainer. Permanent heads of compliance at regional brokers usually earn between £70,000 and £120,000, and more at MGAs and larger groups. Our salary guide has the wider ranges, and what a combined compliance officer and MLRO costs compares the models.
What a Strong Candidate Looks Like
- Compliance experience at a general insurance broker or MGA, not only at an insurer or an advice firm
- Working knowledge of ICOBS, PROD 4, the Consumer Duty in general insurance and CASS 5
- Previous SMF16 approval, or a credible case for a first approval
- For start-ups, experience of a broker authorisation or a move from a network to direct authorisation
- Insurance qualifications such as the Cert CII, Dip CII or ACII, and a compliance qualification where possible
- Enough time, and few enough other clients, to do the job properly
Questions to Ask a Broker Compliance Candidate
- Talk us through how you oversee demands and needs and suitability on a commercial book.
- What did your last fair value review for a distributor or MGA involve, and what changed as a result?
- How do you check the client money calculation, and what would you do if it showed a shortfall?
- How have you overseen appointed representatives, and when did you last recommend ending one?
- What did you change at your last firm when the Consumer Duty came in for commercial customers?
Good answers are specific to broking. Candidates whose experience is mainly at insurers or advice firms often answer in general terms. See interviewing SMF candidates.
When a Broker’s Compliance Officer Leaves
A broker can’t be without compliance oversight. Under the 12-week rule, someone can cover an unexpected vacancy while the firm applies for a permanent replacement, and since April 2026 the cover can continue until the regulator decides, provided the application goes in within 12 weeks. Interim broker compliance officers can usually start within days. See interim compliance officer and MLRO.
Scenario: A founder setting up a small commercial broker in the Midlands is preparing an FCA application and has been told he needs “an SMF16, and an SMF17 if required”. The firm will arrange only commercial general insurance and won’t hold client money at first. We confirm the firm is likely to sit outside the Money Laundering Regulations, so it needs a compliance officer but not an approved MLRO. We shortlist three fractional compliance officers with broker authorisation experience within 72 hours. The appointee helps finish the regulatory business plan and policies, and the firm submits a complete application with its SMF16 named.
How We Recruit for Brokers
We start with the firm: its lines of business, customers, client money, ARs and plans. That decides the days, the experience and whether an MLRO is needed. We then shortlist from approved compliance officers with broker or MGA experience, usually within 72 hours for fractional roles, and help with the Statement of Responsibilities and the approval application. For brokers going directly authorised, see becoming a directly authorised insurance broker. For firms that want an approved person without hiring an employee, see outsourced compliance officer.
Insurance Broker Recruitment
Compliance and senior roles for brokers and MGAs. Every broker search is overseen by Adrian Lawrence FCA
Brokers
Compliance for brokers and MGAs.
→ Outsourced compliance officer → Part-time compliance officerCASS 5 explained →
Authorisation
Starting or leaving a network.
→ SMF authorisation support → Combined SMF16/17Becoming a DA broker →
Insurance
Insurers, MGAs and Lloyd’s.
→ Insurance SMF recruitment → Interim compliance and MLROSMF23 explained →
Guides
For broker boards.
→ Fractional and interim SMF cover → Compliance officer (SMF16)Appointed representatives →
Every broker search is overseen by Adrian Lawrence FCA
Frequently Asked Questions
Does an insurance broker need an SMF16?
Most directly authorised brokers are Core firms and need an approved compliance officer holding SMF16.
Does a general insurance broker need an MLRO?
Usually not, if it only arranges general insurance, because the Money Laundering Regulations apply to life and investment-related insurance. Brokers that also arrange those products usually do.
Can the compliance officer be part-time?
Yes. Most small brokers use a fractional compliance officer for a few days a month, provided the time is enough for the firm’s risks.
Does the Consumer Duty apply to commercial insurance customers?
Yes, proportionately, for policyholders within ICOBS scope. Large risks and reinsurance are excluded.
What does a fractional broker compliance officer cost?
Typically £650 to £1,000 a day, often agreed as a monthly retainer.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He oversees every SMF Capital search. View Adrian’s ICAEW profile.
Need a Compliance Officer for Your Brokerage?
Tell us about your lines of business and where you are with authorisation. We’ll come back with a shortlist plan the same working day.