Regulatory Compliance Health Check

Insurance firms must be able to demonstrate that their regulatory arrangements remain appropriate, their controls are effective and they are delivering good customer outcomes. An independent Compliance Health Check helps identify potential gaps, assess regulatory risks and prioritise improvements, giving firms greater confidence in their compliance framework.

How confident are you in your firm's regulatory compliance arrangements?

Insurance regulation continues to evolve, and maintaining compliance is about much more than having the right policies and procedures filed away.

Firms need to be able to demonstrate that their regulatory arrangements remain appropriate for their business, that their controls are operating effectively and, increasingly, that they understand and can evidence the outcomes being delivered to customers.

The FCA's Consumer Duty requires firms to regularly assess, test, understand and evidence the outcomes customers receive. The FCA Handbook also requires relevant firms within scope of SYSC 6.1.1R to establish, implement and maintain adequate policies and procedures to ensure regulatory compliance.

An ICS Regulatory Compliance Health Check provides an independent assessment of your firm's compliance framework and helps you understand where your arrangements are working well, where there may be gaps and where attention should be prioritised.

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What is a Regulatory Compliance Health Check?

Think of it as a regulatory MOT for your business.

Rather than waiting for a problem, complaint or regulatory concern to expose a weakness, a Health Check takes a structured look across key areas of your regulatory framework.

The objective isn't simply to find faults. It's to give senior management a clearer picture of the firm's current compliance position and provide practical recommendations where improvements can be made.

At the end of the review, you should have a much clearer understanding of:

  • what's working well;
  • where there may be potential gaps or weaknesses;
  • which areas present the greatest regulatory risk;
  • what actions should be prioritised;
  • and where further work or monitoring may be beneficial.

Who is a Regulatory Compliance Health Check for?

A Health Check can be valuable for insurance firms of different sizes and at different stages of development.

It may be particularly useful for:

  • insurance brokers and intermediaries;
  • MGAs and delegated authority businesses;
  • networks and principal firms;
  • firms with Appointed Representatives;
  • businesses experiencing growth or organisational change;
  • firms that have recently acquired or integrated another business; and
  • businesses where senior management wants additional independent assurance.

It can also be useful where it has simply been some time since the firm's overall compliance framework was independently reviewed.

What does the Health Check cover?

The scope can be tailored to the nature, size and complexity of the business. Rather than taking a one-size-fits-all approach, ICS can focus the review on the areas most relevant to the firm's activities and regulatory risk.

Depending on the agreed scope, this could include areas such as:

  • Governance and regulatory oversight
    Considering whether responsibilities are appropriately defined, how regulatory matters are reported and whether senior management has suitable information to provide effective oversight.
  • Consumer Duty
    Considering the firm's arrangements for demonstrating how it is supporting good customer outcomes. The FCA says firms should regularly assess, test, understand and evidence customer outcomes and take action where shortcomings are identified. This makes the quality of a firm's monitoring, MI and governance increasingly important. More on Consumer Duty.
  • Policies, procedures and systems and controls
    Reviewing whether the firm's compliance framework reflects its current activities and whether documented procedures translate effectively into day-to-day business practices.
  • Product governance and distribution
    Considering the firm's approach to product governance and its role within the insurance distribution chain, including the information and oversight supporting those arrangements.
  • Sales processes and client documentation
    Reviewing relevant sales processes and, where included within the agreed scope, sample customer files to consider whether the firm's procedures are being followed in practice.
  • Financial promotions
    Considering the controls surrounding the creation, approval and review of relevant financial promotions.
  • Complaints
    Looking at complaints handling arrangements and how complaints information and emerging themes are used within the firm's wider compliance framework.
  • Customers in vulnerable circumstances
    Considering how the firm's approach to vulnerability is reflected within its processes and customer interactions.
  • Training and competence
    Reviewing the framework used to support and evidence appropriate competence within the business.
  • Appointed Representative oversight
    For principal firms, the Health Check can include consideration of the framework used to oversee Appointed Representatives and the firm's wider control environment.
  • Regulatory reporting and record keeping
    Considering relevant regulatory records and reporting arrangements as part of the overall review.

Why have an independent Health Check?

It can be difficult to objectively assess processes and controls that have developed gradually within a business.  An independent review can bring a fresh perspective.

It can help senior management challenge whether existing arrangements remain appropriate, identify areas that may have received less attention and establish clear priorities for improvement. Crucially, a Health Check shouldn't leave you with a long report and little idea what to do next.

The value comes from turning the findings into practical actions.

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What Will You Gain from a Compliance Health Check?

01

Independent Assessment

A clearer understanding of the strengths and weaknesses of your existing regulatory compliance arrangements.

02

Risk Identification

Greater visibility of potential compliance gaps, regulatory risks and areas requiring further attention.

03

Prioritised Recommendations

Practical guidance on which improvements should be addressed first, helping you focus resources where they matter most.

04

A Clear Route Forward

A foundation for remedial action and, where appropriate, a structured programme of ongoing compliance monitoring.

How ICS can help

ICS understands the regulatory environment in which insurance firms operate and can tailor the Health Check around your business rather than applying a generic compliance checklist.

Our support can include:

  • an independent review of your existing compliance framework;
  • assessment of selected areas of regulatory risk;
  • review of relevant policies, procedures and controls;
  • sample testing or file reviews where appropriate to the agreed scope;
  • identification of potential gaps and areas for improvement;
  • prioritisation of findings according to their significance;
  • practical recommendations and remedial actions;
  • support with implementing agreed improvements; and
  • follow-up reviews where additional assurance is required.

Our aim is to provide a practical and proportionate assessment, giving management greater visibility over the firm's regulatory position and a clear route forward where improvements are identified.

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From Health Check to ongoing assurance

A Regulatory Compliance Health Check provides a snapshot of the firm's compliance framework at a particular point in time.

For firms looking for ongoing assurance, the findings can also help shape a more structured Compliance Monitoring Programme, targeting future monitoring activity towards the areas of greatest regulatory risk.

This creates a natural progression:

Understand where you are today → identify the priorities → address any gaps → monitor on an ongoing basis.
 

When was your last regulatory health check?

Regulatory expectations move on. Businesses change. Products, people, customers and distribution arrangements evolve.

Your compliance framework needs to evolve with them.

An ICS Regulatory Compliance Health Check can provide an independent view of your current arrangements and help you identify where your compliance resources should be focused.

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How is a Health Check different to a Compliance Monitoring Programme?

A Compliance Monitoring Programme is a means of ensuring a firm stays on track of it’s ongoing regulatory responsibilities. A Health Checks is an external review which seeks to test whether, at any point in time, a firm is

  • meeting all its regulatory responsibilities across all areas of the FCA rules;
  • demonstrating issues found in relation to areas such as files reviews, specific areas of regulation have been addressed

CMP = "How do we make sure we stay on track?"
Health Check = "Where are we now?"

 

Don't wait for a regulatory issue to find the gaps.

An independent ICS Regulatory Compliance Health Check can help you understand where you stand today and where attention may be needed.

Book a FREE Consultation

Compliance Health Check FAQs

A regulatory compliance health check is an independent review of a firm's existing compliance arrangements, designed to identify potential gaps, assess regulatory risks and highlight opportunities for improvement.

For insurance firms, this can include reviewing governance arrangements, policies and procedures, systems and controls, Consumer Duty requirements and other areas relevant to their FCA regulatory obligations.

An independent compliance health check can help insurance firms gain greater confidence that their regulatory arrangements remain appropriate and effective.

It provides an opportunity to identify weaknesses before they develop into more significant issues, assess whether controls are working in practice and establish clear priorities for improvement.

The scope of a compliance health check can be tailored to the firm's size, activities and regulatory risks.

Typical areas include governance and oversight, Consumer Duty, policies and procedures, product governance, sales processes, financial promotions, complaints handling, vulnerable customers, training and competence, Appointed Representative oversight and regulatory reporting.

There is no universal FCA requirement for firms to commission an independent compliance health check at a fixed interval.

However, periodic independent reviews can be valuable, particularly following significant business growth, changes in ownership or management, regulatory developments or where existing compliance arrangements have not been reviewed for some time.

The appropriate frequency will depend on the nature, scale and complexity of the business.

A compliance health check provides an independent assessment of a firm's compliance arrangements at a particular point in time. It helps identify existing weaknesses, regulatory risks and areas requiring improvement.

A Compliance Monitoring Programme (CMP), by contrast, provides a structured approach to ongoing compliance oversight, helping firms monitor whether their regulatory responsibilities continue to be met.

Put simply, a health check examines where you are today, while a CMP helps you stay on track.

Yes. An independent compliance health check can help firms identify potential weaknesses in their regulatory arrangements and assess whether appropriate governance, controls and supporting evidence are in place.

Addressing identified gaps can help firms prepare for regulatory engagement and demonstrate a more structured approach to managing compliance risks.

However, a health check does not guarantee a particular outcome from an FCA review.

Where potential compliance weaknesses are identified, ICS can provide practical recommendations and help prioritise the areas requiring attention.

Depending on the agreed scope, support may also include remedial action planning, assistance with implementing improvements and follow-up reviews to assess whether changes have been effective.

Yes. ICS provides independent regulatory compliance health checks as a standalone service, tailored to the firm's requirements.

Where ongoing support would be beneficial, the findings can also help inform a structured Compliance Monitoring Programme, focusing future monitoring activity on areas presenting the greatest regulatory risk.

How Can We Help?

We offer up to two initial consultations without charge, to determine the exact nature of your challenges/concerns. If you would like to try out some of our compliance services before committing we can offer a demo of our Compliance Portal, samples of our Hot TopICS or attendance at one of our Webinars. Thereafter we will agree which of our services are most likely to help you most with your regulatory requirements, agree a package of support (or a one-off project) and send a detailed proposal for your approval. Before, or after, you decide to go ahead, we will introduce you to the Consultant(s) who will agree a diary of contact at times to suit you both.

Please call us on 01892 539600, email us at enquiries(at)insurancecompliance.co.uk, or send us a message using the form for more information or to make an enquiry about any of our compliance services.

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ICS provides a valuable service to us, keeping us updated with regulatory change via regular bulletins and quarterly webinars. Where necessary they have broken down what is required and provided a sounding board for what these changes mean for us personally. We value their assistance with regulatory reporting, as and when we need further support, and having someone on hand who knows our business to provide advice, a second opinion or a view of industry practice where required. We would recommend ICS to other firms. Aaron Greaves Tower Insurance Brokers
My Firm has had the pleasure to have Rob as our Compliance Advisor from ICS for the past 10 plus years and over the years he has proved to be an invaluable asset to my Firm. Rob is meticulous in his approach to managing compliance but at the same time manages to add his own individual flair to the job, making it simple to understand and not overly tedious. My Firm wears the support Rob provides me like a warm blanket and I would recommend him 100%. Nigel Parkinson Clifton Insurance
Elaine is an integral part of our FCA return process, making sure our data is sense-checked before she enters it all on the FCA’s systems and sending us confirmation afterwards that everything’s been done. She provides a top-notch service and is a pleasure to work with. Aaron Myers International Medical Group®
Parliament Hill have been working with ICS for over two years now. The advice and support we receive from the team is always clear and concise in guiding the business to meet all regulatory requirements. They are also a valuable partner in ensuring we stay well informed of future legislative changes which may impact the way we operate. Thank you! Parliament Hill
We engaged ICS to transit from a pre-Brexit authorised foreign firm to the new environment that was created post-Brexit. David and Elaine helped us with our applications, our FCA submissions and our overall compliance training, preparation, and implementation. We feel very lucky to have had David and Elaine help us navigate through the complex regulatory UK framework. Insurance Business Owner
ICS have been a joy to work with and extremely proficient whilst helping with FCA authorisation and regulatory approval. Marie & David understood exactly what was required and allowed me to immerse myself in the process too throughout. I’ll be using them on an ongoing basis too, now that authorisation and regulatory approval has been received. Marie and David are knowledgeable, thorough and extremely good people too. Ed Colville XA Underwriting Solutions Ltd.
DR&P Group have been working with ICS for the last 3 years, supporting the group in several key areas of compliance. Whilst ICS primarily support us on our London Market business following our first Lloyd’s Broker acquisition, they have been able to provide support across a broad spectrum of compliance issues including audits, training and the management of Appointed Representatives.

We have been impressed with ICS ability to interpret regulatory change, their depth of knowledge and most importantly, the way that they complement and work in tandem with our own internal compliance department and our business leaders. Tom Storer DR&P Group
I wholeheartedly recommend the services that ICS provide. ICS, through Elly, has spent time to understand our business and provides guidance and support to negotiate the regulatory landscape. Elly is hugely knowledgeable, approachable, and responsive, and happy to answer questions.

ICS is pro-active in the regulatory space, providing numerous resources including highly relevant bulletins, seminars and webinars. Overall a pleasure to deal with. Specialist Insurance Broker South West England
The guidance received from ICS helped us navigate compliance issues with ease, ensuring that we met all regulatory standards efficiently. The practical solutions they provided have greatly improved our compliance processes and minimised our risk exposure.

We highly recommend ICS to any organisation seeking expert compliance advisory services. Their professionalism, expertise, and commitment to excellence are truly unmatched. Thank you for your support!” Specialist Intermediary South East England
In August 2023 we engaged ICS for compliance advisory services, and the experience has been outstanding. Their deep knowledge and understanding of regulatory requirements have been invaluable to our organisation.

From the very beginning, Elly at ICS demonstrated a thorough understanding of our industry’s unique challenges and tailored her approach to meet our specific needs. In addition, the whole ICS team has been proactive, detail-oriented, and always available to address any concerns or questions we had. Specialist Intermediary South East England
We highly value the regular updates which explain the actions we need to take. These help us anticipate and accommodate regulatory changes and maintain compliance. Insurance Business Owner
We particularly appreciate our dedicated compliance consultant’s visits. He is a key part of our team and helps us feel confident. Insurance Business Owner
We have faith that you will always deliver a high standard of service. Insurance Business Owner
You are always ready to help. Our dedicated consultant gives us tailored advice at our quarterly reviews and the telephone helpline is always available whenever we need a little extra support. Insurance Business Owner
Your 'full service' package gives us unrivalled peace of mind. From the comprehensive compliance manual to the Hot TopICS regulatory updates, you ensure that we are well-informed and able to implement the actions needed to maintain compliance. Insurance Business Owner
We have never been more comfortable with our regulatory status / situation based on the support and guidance we receive from you guys. Jeff Rush Chief Executive, Rush Insurance Services Ltd
Earlier this week I was sent details of what would be required for a Network audit at the end of the month. The amount of documents, policies, procedures and registers required for this were terrifying and would previously have taken me 2 weeks of solid work to pull together, whilst still trying to run the business and look after clients. Because of the work Casey had already done for us though, in only 2 visits, literally everything needed was readily available, up to date and perfect. Can’t thank her enough and wouldn’t hesitate to recommend her to anyone else. Insurance Business Owner
ICS has been invaluable to us and we will continue to use them as our external compliance arm as they are a dedicated professional team with unparalleled expertise in the industry. Insurance Business Owner
Since working with ICS we have complete peace of mind regarding all of our compliance needs. We have worked with others in the past who have not understood our business or our needs. ICS’s service has been exceptional, not only with our regular day to day requirements, but also when we have called on them for support and advice for bespoke projects; indeed they attended an urgent meeting with a moment’s notice. Insurance Business Owner
We have used ICS for 10 years. We are extremely satisfied with the service they provide and with their specialist knowledge and advice on the rules and regulations. Nothing is too much trouble. Help from the friendly team with the RMAR/Gabriel is greatly appreciated. We would not hesitate to recommend them. Insurance Business Owner