The Financial Conduct Authority is sharpening its focus on Managing General Agents (MGAs) and claims handling in 2026, as the Consumer Duty moves from implementation into active supervision and enforcement. For UK insurance brokers and MGA-aligned distributors, that means closer scrutiny of product governance, claims outcomes and customer communication.
The Consumer Duty, introduced in 2023, has dominated most FCA activity since. The regulator's 2026/27 work programme confirms the Duty will remain a priority, with multi-firm reviews examining how firms approach outcomes monitoring, product design, customer journey mapping and consumer understanding.
Why MGAs are in the spotlight
MGAs are often involved in both product development and distribution, which places them directly in the FCA's field of view on product governance. The regulator expects firms not just to comply with rules but to evidence that their products deliver value across the lifecycle of a policy — including at the claims stage.
Claims handling is increasingly seen by the FCA as where the product is tested in practice. For MGAs operating under delegated authority, the regulator expects robust claims frameworks — whether handled in-house or by third-party administrators — with:
- Clear accountability chains
- Consistent reserving and decision-making
- High-quality management information evidencing fair and timely outcomes
- Effective oversight of TPAs and law firms handling claims
What's new in 2026
Several workstreams are converging this year:
- Pure Protection Market Study: the FCA will conclude its market study, examining ways to reduce the protection gap and improve consumer awareness and claims experience.
- Premium Finance Market Study: firm-by-firm Consumer Duty reviews continue, rather than market-wide intervention.
- Wholesale scope clarification: in H1 2026 the FCA is consulting on revisions to the Duty's scope and exemptions, including delineating B2B activity and reliance arrangements within distribution chains.
- Non-UK customers: proposed removal from Consumer Duty scope to reduce regulatory duplication and support UK competitiveness.
- Non-financial misconduct: from 1 September 2026, bullying, harassment and violence fall within the Code of Conduct (COCON) for all FCA-regulated firms.
What insurance brokers should do now
For insurance brokers — particularly those placing business via MGAs — the practical priorities for 2026 are:
- Product oversight: evidence how each product has been reviewed against the fair value outcome and target market definition.
- Claims data: capture and interrogate claims outcomes as part of Consumer Duty monitoring — claims ratios, time-to-settle, complaint rates by product.
- Distribution chain: document the information flow between insurer, MGA and broker, and be ready to demonstrate each firm's role in delivering good outcomes.
- Vulnerable customers: the FCA and ICO are issuing joint guidance on balancing vulnerability identification with data protection obligations in Q1 2026.
The bigger picture
FCA Chief Executive Nikhil Rathi has made clear that the regulator will rely more on the Consumer Duty and supervisory powers than on new rulemaking: "Not every problem is going to be solved quickly by doing big interventions, more rules, bans, guidance." For the insurance sector, that means the Duty itself — and the evidence firms can produce under it — will do more of the heavy lifting going forward.
Disclaimer
This article is for general information only and does not constitute financial, legal or regulatory advice. FCA rules and guidance change frequently. Firms should consult their own compliance function or a qualified regulatory adviser before making any decisions based on this article.
FAQ
What is an MGA?
A Managing General Agent — a firm that underwrites insurance on behalf of an insurer under a delegated authority agreement.
Does the Consumer Duty apply to B2B insurance?
The Duty currently applies to retail customers. The FCA is consulting in H1 2026 on refining the scope — including delineating B2B activity and removing non-UK customers from scope.
When do the non-financial misconduct rules take effect?
1 September 2026 for all FCA-regulated firms (the rules previously applied only to banks).
