Information on section 166 (skilled person) reviews and associated costs in the insurance sector - June 2026

Reference Case Number: FOI2026/01202

Freedom of Information: Right to know request:

Please provide information concerning the number and cost of Section 166 of FSMA reviews in the insurance sector. Please see Annex A for full details of your request.

FCA response:

Section 1

Using page 186 of the 2024/25 annual review (https://landmark-phase.live/publication/annual-reports/annual-report-2024-25.pdf#page=185%3C/a%3E).%3C/p%3E%3Col%3E%3Cli data-list-item-id="e96f1ad16f741dda5b4917390354b9d43">In the year to 31 March 2025, of the nine skilled person reports commissioned in the insurance sector how many were on intermediary (solo regulated) firms and how many were for insurers (dual regulated firms)? In turn a breakdown within these categories please of cases where the regulated firm appointed the skilled person and cases where the FCA appointed the skilled person firm.

The information you are seeking is set out in the table below.

Please note that firms have been categorised based on their primary supervisory portfolio. A large number of firms hold regulatory permissions relating to general insurance, including banks, advisory firms and mortgage intermediaries.

For the purposes of this response, we have used our primary portfolio classification as this is most likely to identify firms for whom general insurance represents their main business activity.

It should also be noted that individual skilled person reports may relate to different aspects of a firm’s business and are not limited to general insurance activities.

Category	No. s166	Firm Contracted	FCA Contracted
Insurance intermediary (solo regulated) firms	3	2	1
Insurers (dual regulated) firms	6	1	5

The annual report then states:

“The aggregate cost incurred by regulated firms for s166 work undertaken in the 2024/25 financial year − including reviews that commenced in previous years and remain in progress − was £44.7m.”

How much of this was spent by insurance intermediary (solo regulated) firms?

Insurance intermediary (solo regulated) firms incurred costs of £880,000.00

3) How much of this was spent by insurers (dual regulated) firms?

Dual regulated insurance firms spent a total amount of £2,206,602.30.

Section 2

Using the four quarterly updates for 2025/26 listed here (https://landmark-phase.live/about/how-we-regulate/supervision/skilled-persons-reviews%3C/a%3E%29 the total for the insurance sector is seven (made up of one in Q1; two in Q2; three in Q3; one in Q4).

In the year to 31 March 2026, of the seven skilled person reports commissioned in the insurance sector how many were on intermediary (solo regulated) firms and how many were for insurers (dual regulated firms)? In turn a breakdown within these categories please of cases where the regulated firm appointed the skilled person and cases where the FCA appointed the skilled person firm.

The requested information can be found in the table below.

Category	No. s166	Firm Contracted	FCA Contracted
Insurance intermediary (solo regulated) firms	2	1	1
Insurers (dual regulated) firms	5	3	2

Finally, only for businesses that fall into the FCA’s ‘insurance sector’, what was the aggregate cost incurred by regulated firms for s166 work undertaken in the 2025/26 financial year – including reviews that commenced in previous years and remain in progress? How much of this was spent by insurance intermediary (solo regulated) firms? How much of this was spent by insurers (dual regulated) firms?

We would like to explain that the way we record and report on the costs of skilled person reviews has changed over time. Historically, we collated and reported on the costs incurred for any review work undertaken during the financial year (including in respect of those reviews yet to complete or spanning multiple years). However, from 2025/26 onwards, we will report on the full cost of any reviews that have completed within that financial year.

Although we hold cost data for individual reviews, this information is not centrally recorded or maintained in the format requested. To identify the total cost incurred in 2025/26 only, we would need to undertake a complex analysis and reconciliation exercise. In our view, would amount to creating new information, which we are not required to do under FOIA.

We would, however, be able to provide information on the total cost of skilled person reviews completed in the 2025/26 in relation to insurance intermediaries and insurers, broken down in line with the categories outlined above. If you would like to receive this information, please let us know in writing and we will treat this a new request under FOIA.

Annex A

Section one

Using page 186 of the 2024/25 annual review (https://landmark-phase.live/publication/annual-reports/annual-report-2024-25.pdf#page=185%3C/em%3E%3C/a%3E%3Cem%3E).%3C/em%3E%3C/p%3E%3Cp%3E%C2%A0%3C/p%3E%3Cp%3E%3Cem%3EIn the year to 31 March 2025, of the nine skilled person reports commissioned in the insurance sector how many were on intermediary (solo regulated) firms and how many were for insurers (dual regulated firms)?

In turn a breakdown within these categories please of cases where the regulated firm appointed the skilled person and cases where the FCA appointed the skilled person firm.

The information can be in a table form (please see attached document).

The annual report then states:

How much of this was spent by insurance intermediary (solo regulated) firms?

How much of this was spent by insurers (dual regulated) firms?

Section two

In the year to 31 March 2026, of the seven skilled person reports commissioned in the insurance sector how many were on intermediary (solo regulated) firms and how many were for insurers (dual regulated firms)?

In turn a breakdown within these categories please of cases where the regulated firm appointed the skilled person and cases where the FCA appointed the skilled person firm.

The information can be in a table form (please see attached document).

Finally, only for businesses that fall into the FCA’s “insurance sector”, what was the aggregate cost incurred by regulated firms for s166 work undertaken in the 2025/26 financial year – including reviews that commenced in previous years and remain in progress?

How much of this was spent by insurance intermediary (solo regulated) firms?

How much of this was spent by insurers (dual regulated) firms?

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Information on section 166 (skilled person) reviews and associated costs in the insurance sector - June 2026

Freedom of Information: Right to know request:

FCA response: