Delegated Authority & Distribution Oversight
Regulatory review of delegated authority arrangements, coverholder and broker oversight, agency agreements, remuneration and distribution chain governance.
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Tell us the business, the markets and your timing. Every enquiry is answered the same business day, with a written proposal: the licence, the requirements, the cost and the timeline.
Your enquiry
What we do
Delegating authority does not delegate regulatory responsibility. Where an insurer grants underwriting authority to an MGA, or a firm distributes through brokers and intermediaries, the regulatory obligations remain with the parties that hold the permissions and influence the customer outcome.
In practice, the arrangements grow commercially faster than the oversight around them. Agency agreements are signed on commercial terms without regulatory review, monitoring becomes an annual audit rather than continuous oversight, and no party can produce evidence of who is accountable for the outcome the customer actually received.
We review delegated authority and distribution chains from the regulatory perspective: how responsibility is allocated, whether the oversight applied is proportionate to the authority granted, and whether the management information produced would satisfy a regulator asking who was in control.
Chain Mapping
We map the full distribution chain and the regulatory role of each party in it.
Agreement Review
We review agency agreements, binders and terms of business from a regulatory standpoint.
Oversight Testing
We test whether monitoring of coverholders, brokers and third parties is proportionate and evidenced.
Governance & MI
We rebuild governance, reporting and escalation so control is demonstrable.
What's Included
Distribution Chain Map
A documented view of every party, its regulatory role and the responsibilities it carries.
Agreement Regulatory Review
Assessment of binders, agency agreements and terms of business against regulatory expectations.
Responsibility Allocation Analysis
Clear articulation of manufacturer, distributor and oversight responsibilities between the parties.
Oversight & Monitoring Programme
Risk-based coverholder and broker monitoring including file testing and thematic review.
Remuneration & Fair Value Review
Assessment of commission and remuneration structures within the distribution chain.
Governance & Management Information
Committee structures, reporting lines and MI that evidence effective control.
Who this service is for
Firm types
- - MGAs and managing general underwriters
- - Insurers delegating underwriting or claims authority
- - Brokers operating delegated arrangements
- - Firms distributing through third party networks
Situations & Triggers
- - Delegated arrangements have outgrown the oversight framework
- - Responsibility allocation between parties is unclear
- - An insurer or partner audit has raised regulatory findings
- - Commission structures require fair value justification
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
Delegated Authority Compliance in 2026: A Practical Guide for MGAs and Insurance Firms
Delegated authority lets insurers place underwriting, claims and administration with MGAs and other firms. The FCA is reviewing delegated and outsourced claims oversight in 2026, with findings expected in early 2027.
Broker Oversight for MGAs in 2026: A Practical FCA Distribution Governance Framework
An MGA does not supervise an independent broker the way a principal supervises an appointed representative, but PROD 4, fair value and Consumer Duty still require it to know how its products are sold and to act when distribution harms value.
Insurance TOBAs and Broker Agency Agreements in 2026: What a Regulatory Review Should Cover
An insurance TOBA should describe the relationship the insurer, MGA and broker actually run. Authority, product information, money handling, remuneration, complaints, audit and exit terms all have regulatory consequences.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
Each party remains responsible for its own regulatory obligations, and delegating a function does not transfer accountability for it. The insurer or delegating party retains responsibility for oversight of the delegated activity, while the delegate remains responsible for the regulated activities it carries on under its own permissions.
Scope and limits of the authority granted, allocation of regulatory responsibilities, product governance roles, data and information exchange obligations, oversight and audit rights, remuneration terms, complaints and claims handling responsibilities, breach notification, and termination and run-off arrangements.
Oversight must be proportionate to the authority granted and the risk presented. Broad underwriting authority over retail products requires substantially more testing than a narrow, low-volume commercial binder. Frequency, depth and sample sizes should be justified by a documented risk assessment.
Commission and remuneration paid throughout a distribution chain form part of the total price a customer pays. Where cumulative remuneration is not justified by the benefits or services delivered, the product is unlikely to represent fair value regardless of how the individual components are described.
Volumes and mix by delegate, loss and claims performance, complaint volumes and root causes, target market adherence, cancellation and lapse rates, fee and commission data, breach and exception reporting, and the results of monitoring and file testing, reported at a frequency the governing body can act on.
Yes. We map every party, review the contractual and regulatory relationships, test the oversight actually applied and provide a prioritised plan to close the gaps we identify.