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Industry Guide

Section 250 Compliance for Insurance Brokers

Insurance brokers authorised by the FCA have SM&CR obligations for their approved persons, but Section 250 of the Crime and Policing Act 2026 extends beyond the existing register. Senior underwriters, lines-of-business heads, and managing directors of coverholders who are not SMF-approved may fall squarely within Section 250's scope. With just weeks to the June 29 deadline, a systematic gap analysis is urgent.

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TL;DR

Insurance Brokers face Section 250 obligations under the Crime and Policing Act 2026. Insurance brokers authorised by the FCA have SM&CR obligations for their approved persons, but Section 250 of the Crime and Policing Act 2026 extends beyond the existing register. Senior underwriters, lines-of-business heads, and managing directors of coverholders who are not SMF-approved may fall squarely within Section 250's scope. With just weeks to the June 29 deadline, a systematic gap analysis is urgent. Typical Section 250 gap: Uncovered principals in a mid-size broker. Key roles in scope: Senior underwriters, Coverholder principals, MGA directors. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and PDF/A-3B board evidence pack generation for insurance brokerage firms.

5–25

Uncovered principals in a mid-size broker

The typical Section 250 gap for a insurance brokerage firm — individuals with significant financial authority who are not SM&CR-approved and need declarations before June 29, 2026.

Why insurance brokers cannot rely on existing SM&CR registers alone

Coverholder and delegated authority principals

Principals at Lloyd's coverholders or firms with binding authority who are not individually FCA-approved represent a classic Section 250 gap. Their authority to bind risk on behalf of an insurer constitutes significant financial influence.

Senior underwriters and risk heads

An underwriter who sets pricing strategy, manages a book of business, and approves non-standard terms is exercising significant financial authority — regardless of whether they hold a formal SMF.

MGA leadership

Managing General Agents often have complex ownership structures. Senior leaders at MGA firms need a clear Section 250 analysis that maps their actual authority to the legislation.

Roles typically in scope for insurance brokerage firms

  • ⚑Senior underwriters
  • ⚑Coverholder principals
  • ⚑MGA directors
  • ⚑Lines-of-business heads
  • ⚑Managing directors without SMF designation

Common questions from insurance brokerage compliance teams

Does Lloyd's membership change our Section 250 obligations?

No. Lloyd's managing agents and coverholders are FCA-regulated and have the same Section 250 obligations as any other authorised firm. Lloyd's own compliance framework does not substitute for the statutory requirement.

We are a small regional broker with 12 staff. Do we have a Section 250 obligation?

Yes, if you are FCA-authorised and have individuals in significant roles outside your SM&CR perimeter. Size is not an exemption. CoverProof Professional (£299/month) is the entry tier for FCA-regulated firms managing their first Section 250 cycle and ongoing obligations beyond it.

Don't let the June 29 deadline catch you exposed.

CoverProof identifies every individual in your brokerage who needs a Section 250 declaration. Zero-login declaration flow means recipients can respond without creating an account. Evidence pack generated automatically.

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