The membership organisation believes no claim discount protection reporting is disproportionate

Broker membership organisation Biba is calling on insurance regulators to review data collection requirements, as brokers raise concerns about the format and deadlines of regulatory data submissions.

At its 2020 manifesto launch yesterday, held at the House of Commons, Biba shared brokers’ worries around data collection that supports supervisory and regulatory reporting requirements – this included sharing the story of one member who was only given two weeks to reply to a comprehensive FCA data request on operational resilience.

With this in mind, Biba is urging regulators, such as the FCA, to review the weight of data they seek from firms, as well as the timescales within which they require it.

Data overload

Alongside this, Biba’s manifesto also highlighted no claim discount (NCD) protection reporting, which brokers submit to the Competition and Markets Authority (CMA) – the membership organisation described this as “disproportionate”.

Biba explained that the current model requires both insurers and brokers to submit an annual compliance declaration, to adhere to the CMA Order (The Private Motor Insurance Market Investigation Order 2015) – this includes providing details of the average NCD tables that are to be used. Typically, this needs to be returned with an Annual Compliance Statement on 1 February every year.

Biba suggested that this approach causes duplication and unnecessarily increases the workload of brokers, especially smaller firms, as instead of the CMA collecting statements just from hundreds of insurers, the authority also receives thousands of data submissions from every intermediary – this information could mirror what insurers have already provided. This “is an unnecessary burden on smaller brokers”, Biba explained.


Biba has, therefore, called on the CMA to revise its protected NCD reporting requirements, so that only the product manufacturers need to supply the annual returns – the organisation believes this will reduce “red tape”.

Stuart Hulbert, joint managing director at Brents Insurance, added: “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.”