Insurance Brokers Code of Practice 2025 Review: What Australians Must Know About Remuneration Disclosure

Choosing an insurance broker in Australia has always required a degree of trust — trust that the professional recommending your cover is acting in your best interests, not their own. In December 2025, an independent review of the Insurance Brokers Code of Practice (IBCOP) delivered 14 recommendations that are reshaping how brokers must disclose their remuneration, manage conflicts of interest, and serve clients across all insurance types, including the long-contested strata sector. For Australian consumers and businesses, understanding these changes is essential to making informed decisions about who manages your insurance.

What Is the Insurance Brokers Code of Practice?

The Insurance Brokers Code of Practice is the self-regulatory framework governing the conduct of insurance brokers who are members of the National Insurance Brokers Association (NIBA). It sets minimum standards for how brokers must communicate with clients, disclose their remuneration, handle complaints, and manage conflicts of interest.

Unlike the General Insurance Code of Practice — which governs insurers directly — the IBCOP applies specifically to the broking profession. Compliance with the Code is a condition of NIBA membership, and NIBA members collectively place the vast majority of commercial and personal insurance in Australia.

The Code is subject to periodic independent review. The most recent review, conducted by cameron.ralph.khoury (CRK), was completed in December 2025 and triggered the most significant proposed reforms to the Code in years.

What the 2025 Independent Review Found

The CRK review was prompted by growing stakeholder concerns about broking practices — particularly in the strata management sector, where some brokers had failed to adjust commission percentages as insurance premiums rose sharply, resulting in disproportionate remuneration increases without corresponding increases in service.

The review also identified a troubling trend in compliance data: remuneration-disclosure breaches rose from 42 in 2023 to 334 in 2024 — nearly an eightfold increase in a single year. This spike signalled that existing disclosure obligations were either poorly understood, inconsistently applied, or insufficiently enforced.

The 14 recommendations delivered by CRK addressed these concerns across several dimensions, including making the Code contractually enforceable, mandating specific disclosure templates, and extending remuneration disclosure obligations to all strata insurance regardless of client classification.

Key Changes in the 2026 Draft Code

Following the CRK review, NIBA released a draft revised Code for public consultation in July 2026. While NIBA supported six of the 14 recommendations outright, it reworked or opposed eight — including proposals to make the Code contractually enforceable and to mandate specific disclosure templates, which NIBA argued were too prescriptive for the diverse range of broking firms.

Despite these differences, the draft Code introduces several significant changes that consumers and businesses should understand.

Extended Strata Remuneration Disclosure

One of the most consequential changes is the extension of remuneration disclosure to all strata insurance — both residential and commercial — regardless of whether the client qualifies as a "retail client" under the Corporations Act 2001. Previously, disclosure obligations were more limited for wholesale or non-retail clients.

The draft also clarifies that in strata arrangements, the "client" is the owners corporation, not the strata manager. This distinction matters because it places the disclosure obligation directly in the relationship between the broker and the body corporate, reducing the risk that remuneration information is filtered or obscured through a strata management intermediary.

Dollar-Amount Disclosure at Invoice Stage

The draft Code requires brokers to disclose their remuneration as a specific dollar amount at the invoice stage, rather than merely as a percentage of the premium. Clients may also request this dollar figure for any insurance product at any time.

This change is significant because percentage-based disclosures can obscure the actual dollar value of a broker's remuneration — particularly when premiums are high. A 15% commission on a $50,000 strata premium represents $7,500 in broker income, a figure that is far more meaningful to a client than a percentage alone.

Prohibition on Contingent Remuneration

Section 7.6 of the draft Code prohibits brokers from receiving contingent remuneration from an insurer when acting on a client's behalf. Contingent remuneration — such as volume bonuses, profit-sharing arrangements, or other payments tied to the volume or profitability of business placed with a particular insurer — creates a structural conflict of interest that can compromise the independence of broker advice.

An exception applies for brokers acting under a binder arrangement without providing client advice, recognising that binder arrangements involve a different principal relationship.

Conflict of Interest Alignment with ASIC RG 181

The draft aligns the Code's definition of conflicts of interest with ASIC Regulatory Guide 181, which governs the management of conflicts of interest for financial services licensees. This alignment brings the broking profession's conflict management standards into closer harmony with the broader financial services regulatory framework.

Pre-Renewal Contact Requirement

The draft introduces a 28-day pre-renewal contact requirement, obliging brokers to contact clients at least 28 days before a policy renewal to discuss coverage, any changes to terms or premiums, and the broker's remuneration for the upcoming period. This gives clients meaningful time to review their options and, if necessary, seek alternative advice.

Common Mistakes When Choosing an Insurance Broker

The reforms highlighted by the 2025 review reflect systemic issues that consumers and businesses have encountered when engaging insurance brokers. Understanding these pitfalls can help you make a better choice.

• Assuming all brokers disclose remuneration equally — Prior to the draft Code reforms, disclosure practices varied significantly. Always ask your broker to confirm their remuneration in dollar terms, not just as a percentage.
• Not questioning strata broker arrangements — In strata settings, the broker is often engaged by the strata manager rather than the owners corporation directly. Confirm that the broker's primary duty is to the owners corporation and that remuneration is disclosed to the body corporate.
• Overlooking contingent remuneration arrangements — Some brokers receive volume bonuses or profit-sharing payments from insurers. Ask directly whether your broker receives any form of contingent remuneration from the insurers they recommend.
• Failing to compare broker proposals — Many businesses engage the same broker year after year without benchmarking their service or remuneration against alternatives. The market is competitive, and comparing proposals can yield better outcomes.
• Ignoring the complaints process — If you have concerns about your broker's conduct, the Code provides a formal complaints mechanism. Unresolved complaints can be escalated to the Australian Financial Complaints Authority (AFCA).

Australian Regulatory Context

Insurance brokers in Australia operate within a layered regulatory framework. At the legislative level, brokers who provide financial product advice must hold an Australian Financial Services Licence (AFSL) issued by ASIC, or operate as an authorised representative of an AFSL holder. This licence imposes obligations around the quality of advice, disclosure of conflicts, and the maintenance of professional standards.

The Corporations Act 2001 and the National Consumer Credit Protection Act 2009 provide the statutory foundation for these obligations. ASIC's Regulatory Guide 181 on conflicts of interest and Regulatory Guide 175 on licensing requirements are particularly relevant to broking conduct.

The IBCOP operates as a self-regulatory layer on top of these statutory obligations. While the Code is not currently contractually enforceable — a point of contention in the 2025 review — NIBA membership and Code compliance remain important signals of professional commitment. The CRK review recommended making the Code contractually enforceable, which would allow clients to rely on Code commitments as terms of their broking agreement. NIBA has not yet adopted this recommendation in the draft Code.

Separately, the General Insurance Code of Practice — which governs insurers rather than brokers — is also undergoing significant reform in 2026, with proposals to make it contractually enforceable and to introduce automatic claim acceptance after 12 months. These parallel reforms reflect a broader regulatory push to strengthen consumer protections across the insurance ecosystem.

Complaints about insurance brokers that cannot be resolved directly can be lodged with AFCA, which provides free, independent dispute resolution for financial services consumers.

Questions to Ask Your Insurance Broker

Whether you are engaging a broker for the first time or reviewing an existing relationship, these questions will help you assess whether your broker is operating to the standards expected under the revised Code.

• What is your remuneration for this policy, expressed as a dollar amount? — A compliant broker should be able to answer this clearly and promptly.
• Do you receive any contingent remuneration, volume bonuses, or profit-sharing payments from any insurer? — This question directly tests for conflicts of interest that the draft Code seeks to prohibit.
• How do you manage conflicts of interest when recommending insurers? — Look for a structured, documented process rather than a vague assurance.
• Are you a NIBA member and do you comply with the Insurance Brokers Code of Practice? — NIBA membership signals a commitment to professional standards.
• How will you contact me before my policy renews, and how far in advance? — The draft Code requires 28 days' notice; a good broker should already be doing this.
• What is your complaints process, and how do I escalate to AFCA if needed? — A transparent broker will explain this without hesitation.
• How many insurers are on your panel, and how do you select which ones to approach for my cover? — A broader panel generally means more competitive options for clients.

How MyMoney® Can Help

Navigating the insurance broking landscape — particularly in light of the 2025 Code review and the evolving remuneration disclosure requirements — requires access to professionals who are committed to transparency and client-first conduct.

MyMoney® connects Australian consumers and businesses with qualified, vetted insurance brokers who operate to the highest professional standards. Whether you need cover for your business, your strata property, your income, or your life, our platform makes it easy to compare proposals from multiple brokers and make an informed decision.

Post a Brief on MyMoney® to describe your insurance needs and receive tailored proposals from compliant, experienced brokers. Or Browse Insurance Brokers on our platform to explore professionals in your area and review their credentials before making contact.

The right insurance broker is one who discloses their remuneration clearly, manages conflicts transparently, and places your interests first. MyMoney® helps you find them.