RWA IDD Survey – The White Paper

For the past few months, the team at RWA has been actively promoting awareness of the FCA Insurance Distribution Directive (IDD) Consultation Paper (CP17/7), to the point where arguably, we were at risk of becoming a bit of a bore…


The answer is simple. Every insurance professional will be affected by changes to FCA policies. The FCA consultation process is our collective opportunity to feedback on proposed changes in order to shape the future of the industry, and to date, this opportunity has been largely overlooked.

For example, in April 2016 the FCA issued a Consultation Paper on the subject of Renewal Transparency.

The response from the insurance broking market was awful and no one remarked on the inconsistencies in the proposed policy statement and the activity of giving advice to clients.

The resulting policy statement was not ideal for the authorised firms giving advice nor for the consumer.

RWA is determined to not let this happen again.

A different approach

During April 2017, members of the FCA GI Supervision team joined the panel at five Aviva / RWA / Edwin Coe Masterclass events, during which we asked the 200 or so delegates to support the FCA’s consultation process.

Each delegate was asked how we could make the process simpler, and based on the feedback received, we settled on an RWA digital survey, which drew the relevant detail from the Consultation Paper and guided respondents through the implications of each proposal.

The survey, which was open to anyone, was actively promoted to our clients and contacts, inviting them to take time out to consider the FCA’s ideas on implementing the Insurance Distribution Directive.

We received an encouraging reaction to this approach, with 150 individual responses from 122 different firms.

The RWA IDD White Paper

The survey responses have been submitted in full to the FCA ahead of the 5th June deadline, and are currently being considered along with those submitted directly (those requesting to remain anonymous had their personal and corporate details removed).

The team at RWA has also read through the survey responses and prepared a white paper, which contains a summary, in the form of a Masterclass Commentary, of the most pertinent comments and prevailing opinions.

Whilst the actual output of the FCA’s consultation process will not be known until the Policy Statement appears around September of this year, the RWA IDD white paper certainly makes for interesting reading.

The IDD will have widespread repercussions for the industry, and whilst no-one can offer concrete guarantees as to exactly what these will be at this stage, the white paper provides an excellent indication of the shared concerns of industry peers.

Download the white paper here.

Consultancy support

Insurance Brokers are faced with two alternatives with regards to the consultation process.

The first option is to bury your head in the sand, carry on as normal, and wait to be told what to do, at which point any amendments to processes and procedures may be hugely demanding.

Option two is to read through the white paper, and evaluate the relevance of each question to your business practices.

Many of the proposed changes may well fall into the ‘common sense’ category, so why not consider them now, ahead of the publication of a Policy Statement. Insurance Brokers have an opportunity to get ahead of the curve, and mitigate any disruption to working practices, which is something that we at RWA are strongly encouraging.

Should you have any concerns regarding the IDD, or questions arising from the white paper, we are offering a helpline and consultancy support.


We would like to thank the firms that took the time to respond to the RWA IDD survey. Respondents can take pride in helping to shape the future of the insurance industry. The outcomes of the IDD consultation will become law in February of 2018, and whatever the outcome, at least respondents can be confident that they have had their say.

Get in contact if you have any questions. We can’t say for definite what the IDD Policy Statement will contain as it has not been published, but we can help identify how it will affect your business, and what steps you can take now to prepare.

RWA is operating a helpdesk for those firms who have questions, or would like consultancy support. Please email your IDD queries to:

Robin Wood
Chartered Insurance Practitioner


About the author

Robin is the founder of RWA. He is an acknowledged expert on an insurance broker’s duties and Conduct Standards and Risk Management and has been an expert witness to the courts on a number of reported cases, including Environcom v Miles Smith, The Café De Lecq case and Eurokey v Giles.

Robin has written a number of important books on topics such as Training & Competence, The Duty of an Insurance Broker, The Insurance Act and Professional Standards of Insurance Brokers. A regular speaker at industry conference events and Masterclasses, Robin is an engaging presenter who is known for filling a room and providing a challenging and effective delivery.

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