The Insurance Brokers Code Compliance Committee (IBCCC) has sanctioned three insurance brokers for breaches of their obligation to submit Annual Compliance Statements, a crucial element of Code compliance.
All three brokers failed to meet the 31 March 2025 deadline – the third consecutive year to miss the deadline – despite multiple reminders and clear guidance from both the IBCCC and the National Insurance Brokers Association (NIBA).
Chair of the IBCCC, Oscar Shub, highlighted the importance of the obligation that the brokers failed to meet.
“Annual Compliance Statements are not optional. They are a basic and essential obligation for every insurance broker that subscribes to the Code,” Mr Shub said.
“When brokers repeatedly fail to meet this commitment, it raises real questions about their systems, their governance, and ultimately, their commitment to professionalism.”
Each broker cited different reasons for their delays, ranging from system issues to competing work pressures. But the IBCCC found none of the explanations sufficient, given the importance of the obligation and the time brokers had to prepare.
“Every business faces competing priorities. But three consecutive years of missing a deadline signals a deeper problem. This was not just a one-off oversight,” Mr Shub said.
The IBCCC noted industry-wide improvements in reporting timeliness over the past three years, with the number of brokers missing the deadline falling from 86 in 2023 to 11 in 2024.
Its repeated warnings and widespread engagement resulted in most brokers who had previously missed the deadline reporting on time in 2025.
Each of the three sanctioned brokers eventually submitted their statements and have since taken steps to improve internal processes. The steps included introducing fixing administrative issues and reviewing internal compliance systems.
The IBCCC welcomed the improvements but stressed that they should have come much earlier, and that compliance cannot be left until the last minute.
“We appreciate the efforts to put things right, but brokers shouldn’t be scrambling after the deadline has passed. They knew of the deadline and should have been able to meet it,” Mr Shub said.
“But in cases where a broker anticipates missing a deadline, early engagement is key, especially if the broker needs support or extensions. These brokers did not reach out.”
The IBCCC has sanctioned each broker by referring their non-compliance to NIBA for further action under its membership rules.
“This outcome should serve as a warning to all brokers. Timely reporting is not a box-ticking exercise – it reflects the integrity of your business and your commitment to the Code,” Mr Shub said.
The IBCCC continues to monitor compliance across the industry and expects brokers to maintain robust systems that support timely and effective reporting.
Read the summary of the case.
About us:
The Insurance Brokers Code Compliance Committee is an independent body that monitors compliance with the Insurance Brokers Code of Practice. Its purpose is to ensure brokers maintain consistent and high-quality service standards for the benefit of clients, and to promote trust and confidence in the insurance broking industry.
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