HM Treasury has released the record of its April 2026 Regulatory Perimeter Meeting with the FCA, outlining the regulator’s latest thinking on perimeter issues and areas where further policy development may be needed. Although some topics may not be relevant to the day-to-day activities of most insurance brokers, the nature of the discussions is relevant to insurance intermediaries as the FCA remains focused on emerging risks, consumer protection, accountability, financial promotions and the use of new technology across financial services.
Key themes raised by the FCA
Deferred Payment Credit (Buy Now Pay Later) The FCA confirmed that Deferred Payment Credit formally came under its oversight on 15 July 2026. While BNPL may not be central to most insurance distribution models, the change is a useful reminder that payment arrangements affecting consumers can move into regulation where the FCA identifies potential harm. Brokers should remain alert to how premium finance, instalment options and third-party payment solutions are presented, explained and governed.
Artificial Intelligence (AI) The FCA emphasised the rapid adoption of AI and the need for regulatory frameworks that can respond quickly. For brokers, this is relevant where AI or automation is used in customer journeys, marketing, renewals, claims support, file reviews, compliance monitoring or MI. Firms should be able to explain how these tools are overseen, how customer outcomes are monitored, and how risks such as bias, poor records or unclear communications are managed.
Prediction Markets Although the commentary in relation to prediction market products is unlikely to directly affect most general insurance intermediaries, it reinforces the need for care where firms introduce customers to products, services or partners outside their core permissions. Brokers should consider whether referral or adjacent arrangements could create confusion about what is regulated and who is responsible.
Senior Managers & Certification Regime (SM&CR) It was noted that not all firm types currently fall under SM&CR and that Government may consider extending the regime. Insurance intermediaries are already familiar with individual accountability expectations, but the discussion reinforces the importance of clear governance, documented responsibility, effective oversight of Appointed Representatives and Introducer Appointed Representatives, and evidence that senior managers understand the risks they own.
Financial Influencers (“Finfluencers”) The FCA raised concerns about fraudulent online financial influencers and the current limits on its ability to compel social media platforms to remove harmful content. For brokers, the relevance is wider than specific insurance promotions. Website content, social media posts, introducer activity, testimonials, lead generation and third-party marketing should be accurate, fair, clear and not misleading, with suitable controls over who communicates on the firm’s behalf.
What this means for firms
For insurance brokers and intermediaries, the meeting is a reminder that regulatory change is not limited to rules directly aimed at the general insurance sector. The FCA’s focus on emerging risks, financial promotions, governance, technology and accountability can still affect brokers’ business models, customer journeys and oversight arrangements.
Firms should review how they monitor activities around the edge of their permissions, including premium finance, AI tools, introducer and referral arrangements, social media activity, customer communications and AR oversight. The message is clear: perimeter issues are evolving quickly, and firms should be ready to evidence that they understand where regulatory risk may arise and how it is being managed.