Insurance regulation will not get simpler before 1 January 2027, when the new Insurance Brokers Code of Practice starts. Brokers who cope will build one current view of their obligations now, rather than wait for reform.
This follows the Plenary 2 panel on regulation and technology at the NIBA Convention, where speakers agreed that the system is heavy in some places and thin in others.
Key facts
• 1 January 2027: the new Insurance Brokers Code of Practice starts.
• 28 days: the minimum notice before renewal, up from 14.
• Record-keeping becomes a Code obligation.
• 30,000+ obligations across 25 authorities and 300 instruments in general insurance (Insurance Council of Australia).
• $2.5-3.5 billion a year: the cost of regulation, or 4-6% of premium written (Insurance Council of Australia).
• 36,022 general insurance complaints to AFCA in 2025-26, up 5%.
What changes for insurance brokers on 1 January 2027?
• Brokers must contact clients at least 28 days before renewal, up from 14.
• Record-keeping moves from good practice to a Code obligation.
• Automatic remuneration disclosure extends to all strata insurance.
• Protections for clients experiencing vulnerability are expanded.
• The Code is rewritten in plain English and reviewed at least every five years.
NIBA said systems-heavy changes have a 12-month transition.
Why is insurance regulation hard to keep up with?
It is heavy where rules are settled and thin where risk is growing. Conduct is where the weight has landed. The Royal Commission and the 2022 floods each brought a wave of intervention, and firms now carry the sum of both. An estimate cited on the panel puts a broker's core obligations at about 328.
The newest risks have the least regulation. The panel named AI, privacy, data security, identity data and claims farmers as gaps. Claims farmers are the clearest case. The panel said many make no claim decisions and so need no AFSL, yet they can inflate claim costs and worsen outcomes for customers. ASIC's 2026-27 Corporate Plan names claims intermediaries in disaster-affected communities as a consumer protection priority for the first time.
Why can't insurance brokers wait for regulatory reform?
1. Reform is slow. The panel put the time from a trigger event to enacted change at three to seven years.
2. Rules follow harm. NIBA's position is that without evidence of harm, extra obligations add cost without adding protection. That is a fair test, and it means new gaps are usually closed after customers are affected, not before.
3. New obligations arrive first. The 28-day renewal notice and record-keeping rules start before any wider simplification.
Until the rules catch up, the firm carries the risk.
What do complaints tell brokers about customer expectations?
AFCA recorded 36,022 general insurance complaints in 2025-26, up 5% on the year before. The panel pointed to slow claims, temporary accommodation that ends before a rebuild finishes, and cash settlements that do not cover repairs, along with cost-of-living pressure. AFCA's advice to insurers was to explain premium increases at renewal.
Most of these causes are communication and process, which a firm can control and can evidence.
How can a broker build one view of its obligations?
1. One register. List every obligation that applies to your firm, from the Corporations Act and Privacy Act to sanctions law and the Code. Add the third parties you rely on, such as authorised representatives, distributors and technology vendors. Give each item one owner.
2. Rank by risk. Not every obligation carries the same weight. Rank them by potential harm to clients and consequence to the firm, and put effort where it matters most. AI can help find patterns here, with a person making the call.
3. Evidence for each. Keep the records, attestations and audit results you could show a regulator or a complaint reviewer.
4. Alerts. Schedule attestations, trigger audits and flag anything overdue, so nothing depends on memory. Software does this tracking better than spreadsheets.
Accountability does not move. A person is still responsible for each decision, must be able to explain it, and needs the records to support it.
Do insurance brokers need their own AI rules?
Yes, because no rule yet covers how brokers use AI. The panel noted that firms are putting client and firm IP into US-owned models with no Australian regulatory protection, and cited one core-systems vendor as holding about three-quarters of the market. Both are concentration risks.
Until a regulator acts, write your own rules. Decide what data may go into a tool, who approves a new tool, who is accountable for its output, and how you would explain its use to a client or to AFCA.
Where should brokers start before 1 January 2027?
Start with what has a date, then work outward.
1. Check how your systems handle the 28-day renewal notice.
2. Review what records you keep, and where.
3. Build the register around those two obligations, then extend it.
4. Write a one-page AI policy.
The new Code shows what good regulation looks like: evidence-led, in plain English, and without repeating what the law already requires. Firms that can show their own evidence will be well placed when the next rules arrive.
Frequently asked questions
When does the new Insurance Brokers Code of Practice start?
On 1 January 2027. NIBA said systems-heavy changes have a 12-month transition.
What is the new renewal notice period for insurance brokers?
Brokers must contact clients at least 28 days before renewal, up from 14.
How many regulatory obligations do insurance brokers face?
The Insurance Council of Australia counts more than 30,000 obligations across general insurance. An estimate cited at the NIBA Convention puts a broker's core obligations at about 328.
Curium's compliance platform brings obligations, registers and controls into one place, helping insurance brokers maintain a clear view of their compliance responsibilities.
Do insurance brokers need an AI policy?
No specific rule covers broker use of AI yet, so a written policy on data, approval and accountability is the way to show control.
Sources
Checked 27 October 2026.
• Insurance Council of Australia, Regulation costing insurance customers up to $3.5 billion a year (7 November 2025): $2.5-3.5 billion, 4-6% of premium, 30,000 obligations, 25 authorities, 300 instruments.
• AFCA preliminary 2025-26 data, as reported by Region: 36,022 general insurance complaints, up 5%. Preliminary and subject to revision.
• Insurance Business: 1 January 2027 start, record-keeping as a Code obligation, and NIBA's evidence-of-harm position.
• NIBA CEO Richard Klipin, A code of practice is measured by what clients experience with their broker (Insurance Business): renewal notice from 14 to 28 days.
• Insurance Business: claims intermediaries named in ASIC's Corporate Plan 2026-27.
From the NIBA Convention panel and Code launch, not found in published sources: the three to seven year reform lag, the 328 broker obligations, the claims farmer AFSL point, the complaint drivers, AFCA's renewal advice, the AI and vendor concentration points and the 12-month transition.\
Book a demo to see how Curium can help your team manage its obligations and compliance workflows in one place.
Author:
Tetiana George, CEO of Curium, Co-Chair of Insurtech Australia and member of ASIC Digital Finance Advisory Committee. LinkedIn Profile.