The short answer
A UK insurance broker should settle who approves its marketing before an agency writes a word. The FCA's rules in ICOBS 2.2 require a firm's communications, including financial promotions, to be clear, fair and not misleading, and an approver must take reasonable steps first. Put five questions to the compliance function, in order, and give the agency the answers as part of the brief.
Key takeaways
- The first test of an agency is how it behaves when a line is struck out, not how its brokerage portfolio looks.
- Ask compliance who approves, how long it takes and what record is kept, then put the answers in the brief.
- Claims about price and speed need an evidence trail the firm holds, so ask the agency how it handles one.
- Approval time is a fixed step in the plan, and a supplier who ignores it will miss dates or publish early.
- If the firm cannot yet say who approves a line, the first spend is on that answer.
Picture a broker with twenty-two staff, invented for this example. The managing partner hires an agency to refresh the site, and the agency's first draft arrives in a week with a line on the home page promising “the cheapest cover in the county”. It reads well. Nobody at the firm can say who is meant to approve it, so it sits in an inbox for three weeks while the launch date passes. The delay was not the agency's fault and it was not the compliance officer's either. It came from a brief that never said how a UK insurance practice signs off what it publishes. This article is about writing that part of the brief first.
Five questions, asked in this order
The order matters, because each answer changes what the next question means. Put these to the firm's compliance function, or to whoever holds that role, before the agency is shortlisted. They are questions, not findings. This article does not say what any firm's permissions are, because that depends on its own authorisation and arrangements, and only the firm can answer.
| Step | Question for compliance | What goes in the brief |
|---|---|---|
| 1 | Who signs off a page or an advert? | A named role, not a department |
| 2 | Is that the firm, or a principal or another party? | The route the agency must send drafts down |
| 3 | How long does a typical item take to come back? | A fixed step in the project plan |
| 4 | What record of approval is kept? | The agency stores the signed-off version |
| 5 | What happens if a published line is later found wanting? | Who can take it down, and how fast |
What the rule asks for
The FCA's rule is that communications must be clear, fair and not misleading, and the duty sits with the firm, not with its supplier. In ICOBS 2.2, the part of the Handbook covering communications and financial promotions for non-investment insurance, the FCA says a firm must ensure the information it communicates, including a financial promotion, meets that standard. Before a firm approves a promotion, the Handbook adds, it must take reasonable steps to check it does, and if it later becomes aware that it does not, it must withdraw its approval. ICOBS 2.2 on the FCA Handbook is short enough for a managing partner to read in full, and the current text is what counts, not this summary.
For an agency, the practical consequence is plain. It cannot decide that a line is fine. It can propose and evidence, and the firm decides. An agency that treats approval as friction to be minimised has misunderstood the job. One that builds the step into its process is telling you it has done this before.
Five made-up lines, marked
The quickest way to test an agency is to hand it a draft and see which lines it asks about. The table below uses invented website lines. It does not say that any of them breaches a rule. It shows the question each one should raise, and a supplier worth hiring raises it before the firm has to.
| Invented line | Question it should raise | Who answers |
|---|---|---|
| “The cheapest cover in the county” | Cheapest for whom, and on what evidence? What do most customers who respond actually get? | Firm, with its pricing data |
| “Trusted by hundreds of local businesses” | Can the firm show the count today, and does it say who counts as a client? | Firm |
| “Complete protection for your premises” | Does the page say what the cover does not include? | Compliance |
| “A quote in two minutes” | True for every product on the page, or only some? | Firm |
| “Award-winning broker” | Which award, from whom, and in which year? | Firm |
Notice who answers. In four of the five rows the firm holds the evidence, so the agency cannot supply it. What the agency can do is ask the question, record the reply and refuse to publish a line nobody has stood behind. That behaviour is the thing to hire for.
What to ask the agency
Ask how it has worked to an approval step before, and listen for specifics. A good answer names the stages: draft, evidence, sign-off, version kept. A weak answer talks about being sector experienced and says nothing about process. Ask what the agency does when a line is struck out at the last stage, and whether it can show how it stores the approved copy. The answers matter more than the list of insurance firms on its site, since a list tells you who the agency sold to, not how it behaved.
The checks we run on a specialist before introducing one are on our page for insurance brokerages. How we introduce one specialist, and how the fee works, is set out in how it works.
What approval does to a timetable
Approval is a fixed step, so a plan that leaves it out is a plan with a hidden delay. Take the invented broker again. Suppose compliance says a page usually comes back in five working days. A six-page refresh written one page at a time would then take six weeks on approval alone, while sending all six together might take two. Neither is right in general. The point is that the choice exists, and the agency should raise it. If a supplier quotes a launch date without asking how approval works, treat the date as a guess.
A first month with approval built in
A good agency's first month looks slower than a poor one's, and then it stops being slow. Stay with the invented broker. In week one the agency does not write anything. It asks for the approval answers and collects the claims the firm already makes, then asks which of them the firm can evidence today. In week two it sends one page, not six, so that the firm's approver can show how much comment a page really draws. In week three it adjusts its drafting to the comments it received. By week four it can quote a turnaround it has measured instead of one it hoped for.
Compare that with an agency that delivers six pages in week two. It looks fast. It has also guessed at the approver's taste six times, and each wrong guess comes back as rework the firm pays for. The managing partner cannot see the difference on a proposal. The difference shows only in how the first fortnight is planned, which is why it is worth asking about before signing.
What to ask on the first call
Four questions on the first call tell a partner more than the case studies do. Ask who at the agency will be on the account day to day and whether that person has worked to a written approval step. Ask what the agency does when two people at the firm disagree about a line. Ask how it keeps the version that was signed off separate from the working drafts. Ask what it would need from the firm to start in a fortnight. An agency that answers each in a sentence has a process. One that answers with an enthusiasm about insurance has a pitch, and a pitch is not the thing the firm is buying.
Before you brief anyone
Want a specialist who works to your sign-off?
Free to your firm. The agency pays us, and only if the relationship works, so we have no reason to favour a supplier that skips the approval step.
Get a recommendationHanding the answers to the agency
The approval answers belong in the brief as a one-page section the agency must acknowledge. State the named approver, the route drafts take, the expected turnaround and the record to be kept. Ask the agency to confirm in writing that it has read the section. Ask the agency to price approval time as its own line too. The same discipline of splitting a quote into separately priced lines is argued in what a recruitment agency should pay for a new website, and it carries over: a supplier that will not show approval as a line has probably not allowed for it.
When not to hire yet
Do not brief an agency until the firm can say who approves a line. If compliance cannot name the approver or the route, or if the answer is that it depends, the first piece of work is internal and costs a conversation. A supplier hired before that point will either wait or guess. And if the only goal is to refresh pages the firm already approved, a smaller job may do. For the hours-based test of whether outside help is needed at all, see when a firm should stop outsourcing marketing.
Frequently asked questions
What insurance brokers ask about choosing an agency.
Does an insurance broker have to approve what its agency writes?
Where a UK broker is authorised, its communications to clients are subject to the FCA's rule that they be clear, fair and not misleading, and that responsibility does not move to a supplier. Who gives formal approval inside the firm is a matter for its compliance function. Ask it before the brief goes out, and write the answer into the brief.
Can an agency write insurance copy without sector experience?
It can write fluent copy, but fluent copy is not the test. The test is whether the agency will work to an approval step and keep a record of which version was signed off. Ask for an example of a regulated client's approval process in its own words.
What should a broker ask an agency about claims it wants to make?
Ask where each claim comes from and who at the broker has agreed it. A line such as a best price or a fast quote needs evidence the firm holds, and the FCA's guidance on pricing claims in ICOBS 2.2 is the place to start. The agency should be able to show the evidence trail, not just the sentence.
How long does approval add to a marketing project?
It depends on how the firm approves things, so the honest answer is to measure it. Ask compliance how long a typical page takes, then build that into the plan as a fixed step. A supplier who has not allowed for it will either miss the date or publish early.
Should a broker use a general agency or a specialist?
Either can work. A specialist saves explanation time on the approval step, while a general agency can be fine if the broker supplies a clear approval route and signs off every line. The deciding factor is how the supplier handles being told no, not how many brokers it lists.
Sources and useful reading
- FCA Handbook, ICOBS 2.2: communications to clients and financial promotions, for the clear, fair and not misleading standard, the duty on an approver and the guidance on pricing claims.
- FCA, financial promotions and adverts, for the regulator's wider material on promotions.
This article is commercial decision support and is not legal or regulatory advice. It does not say what any firm's permissions are or who must approve its marketing, and a firm should ask its own compliance function. The scenario and the draft lines are invented to show the method. The FCA rules are summarised from search results, not from a full reading of the Handbook, so read the current text before relying on them. Sources were located on 18 October 2026.