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Overview
From 9 July 2025, legislation requires advisers to obtain explicit client consent before receiving insurance commissions (monetary benefits). This affects how new insurance advice is documented and accepted.
Legislative Requirements
To receive an insurance commission payment for any new policy where the upfront commission would be paid on or after 9 July 2025, clients must provide consent after receiving the following disclosures:
Insurer name
Commission amount (as a percentage of the premium)
Expected frequency of commission payments
📌Note
If the frequency is less than disclosed, consent remains valid, but it cannot be more frequent than disclosed.
Nature of any services to be provided in relation to the policy (if any)
Clients must also be informed that:
Consent is required by law before commissions can be paid
Consent, once given, is irrevocable
Consent remains valid for the life of the policy as long as premiums continue to be paid
⚠️If these conditions are not met, advisers cannot legally receive commission payments.
💡The legislation makes it clear that if any of the above is already disclosed to the client as part of providing them with advice, it does not need to be specifically disclosed again as part of obtaining their consent. It also includes that consent can be obtained as part of the existing advice process, as long as the above requirements have been met.
Impact on Advice
Advice documents generally include most of this information already.
ALREADY IN SOA/ROA
Name of the Insurer
Rate of Monetary Benefit (for Personal Insurance this should be expressed as a percentage of the policy cost payable)
The Frequency which the Monetary Benefit will be paid, if it is not a one-off payment
However, specific statements about legal requirements and irrevocability of consent must also be included.
If a client signs an SOA or ROA before 9 July but pays the first premium after this date, the new requirements will still apply.
⚠️Missing these disclosures may prevent you from receiving commissions.
What We Have Done in AdviserLogic
We updated the Base Statement of Advice (SOA) and Record of Advice (ROA) templates to include all legislative requirements without adding unnecessary complexity to your workflow from May 28 2025 to ensure you are compliant.
Insurer Name
Already included in SOA and ROA templates.
Commission Rate (as a %)
Already included in existing commission tables. Ensure you enter your commission percentages for the relevant insurance products.
Frequency of Commission Payments
Updated wording in the Insurance Commissions section now clarifies:Upfront commissions are paid after the first premium is received.
Ongoing commissions are paid at the same frequency as the client’s premium payments (or slower, never faster).
Key Policy and Commission Details
The 'Cost of My Advice > Insurance Commissions' section:
Insurer name and commission rate are already included in the SOA and ROA templates.
Updated wording now clarifies that upfront commissions are paid when the first premium is received and that ongoing commissions align with the frequency of premium payments.
Services Disclosure
Two optional bullet points have been added to the Authority to Proceed (ATP) :
A statement that consent is a legal requirement before commissions can be paid, followed by a statement that consent, once given, is irrevocable and remains valid for the life of the policy
A section for listing services provided in relation to the insurance product
Example text now included in ATP:
👉 This bullet can be removed if no services are applicable.
Dynamic Text Handling
Consent wording dynamically adjusts based on whether upfront and/or ongoing commissions are included.
If no commissions are entered against the product, these consent statements will not appear.
This ensures compliance only where required and avoids unnecessary text in other scenarios.
ROA Considerations
AdviserLogic’s default ROA includes the ATP section with signature fields, making it suitable when an ROA is signed for insurance recommendations.
If no commission is disclosed in the ROA (e.g., no change scenarios), consent text will not appear.
Next Steps
If you are using custom templates, please review and update them to include the new disclosures and consent wording.
Alternatively, switch to the updated Base SOA and ROA templates in AdviserLogic to ensure compliance.