Reform of regulatory data collection requirements


BIBA members have expressed numerous concerns about how their regulators collect data to support their supervisory and regulatory reporting requirements which have led BIBA to conclude that an overhaul of those processes is overdue.

Complaints have been raised about the format and deadlines. In one case members were given only two weeks to reply to a comprehensive FCA data request on operational resilience, putting a lot of pressure on firms and affecting productivity.

No Claim Discount (NCD) protection reporting by insurance brokers to the CMA is also disproportionate. 


Currently a declaration is required from both insurers and brokers on an annual basis, confirming compliance with the CMA Order (The Private Motor Insurance Market Investigation Order 2015) and providing details of the average NCD tables that are to be used. This needs to be returned with an Annual Compliance Statement on 1 February each year.

This means that rather than the CMA simply requiring statements from one hundred or so insurers, they will receive thousands of submissions of data from every intermediary that they have also received from insurers and is an unnecessary burden on smaller brokers.


  • For the regulators to review the weight of data they seek from firms and the timescales within which they require it.
  • For the CMA to revise its protected NCD reporting requirements, so that only the product manufacturer need supply the annual returns so reducing red tape

“It is right that small brokers are required to submit relevant reports on their business to the regulator. However, in the last year, we have seen demands for significant amounts of data with very short timescales in which to reply. This is challenging for any small broker. I hope the regulators can recognise that the burden they impose affects productivity and look to gather information more effectively.”

Joint Managing Director, Brents Insurance

BIBA has more than 1,800 individually FCA regulated firms registered as members. 

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