NIBA Insurance Brokers Code of Practice 2026: Remuneration Disclosure and Contingent Commission Reform in Australia

If you use an insurance broker in Australia, significant changes to how brokers must disclose their remuneration are underway. The National Insurance Brokers Association (NIBA) released a draft revised Insurance Brokers Code of Practice (IBCOP) in July 2026, following an independent review by cameron.ralph.khoury (CRK) in December 2025. The proposed reforms — including mandatory dollar-amount remuneration disclosure and a ban on contingent commissions — represent the most substantial overhaul of broker conduct standards in years. Understanding these changes will help you make more informed decisions when choosing and working with an insurance broker.

What Is the Insurance Brokers Code of Practice?

The Insurance Brokers Code of Practice (IBCOP) is a self-regulatory framework administered by NIBA that sets minimum standards of conduct for insurance brokers in Australia. Brokers who subscribe to the Code commit to meeting standards that go beyond the minimum legal requirements under the Corporations Act 2001 and ASIC's regulatory guidance.

The Code covers areas including client communication, conflict of interest management, complaints handling, and remuneration disclosure. Compliance with the Code is monitored by the Insurance Brokers Code Compliance Committee (IBCCC), which can investigate complaints and impose sanctions on non-compliant brokers.

The 2026 review was triggered by growing concerns about transparency in broker remuneration, particularly in the strata insurance sector, and by broader regulatory pressure from ASIC to align industry conduct standards with the regulator's expectations under Regulatory Guide 181 (Conflicts of Interest).

Key Changes in the 2026 Draft Code

The July 2026 draft IBCOP introduces several significant reforms that will affect how brokers interact with individual and small business clients:

• Dollar-amount remuneration disclosure — Brokers will be required to disclose their remuneration as a specific dollar amount at the invoice stage, rather than merely as a percentage of the premium. This change is designed to make the cost of broker services immediately transparent to clients.
• Universal disclosure for individuals and small businesses — The new disclosure obligations will apply to all individual and small business clients, regardless of the type of insurance product. Previously, disclosure requirements varied by product type.
• Extended strata insurance disclosure — Disclosure obligations have been extended to all strata insurance, ensuring that owners corporations — not just strata managers — receive clear information about broker compensation.
• Ban on contingent remuneration — The draft code proposes to prohibit brokers from receiving contingent remuneration — such as volume bonuses, profit-sharing arrangements, or other payments that depend on the volume or profitability of business placed with a particular insurer — when acting on a client's behalf.
• 28-day pre-renewal contact requirement — Brokers must contact clients at least 28 days before a policy renewal, providing sufficient time for clients to review their coverage and remuneration details before the policy automatically renews.
• Alignment with ASIC RG 181 — The draft code seeks to align broker conflict of interest management standards more closely with ASIC's Regulatory Guide 181, which sets out how financial services licensees should manage conflicts of interest.

Why Contingent Commissions Are a Concern

Contingent remuneration — also known as volume bonuses or profit-sharing — is a payment arrangement where an insurer pays a broker additional remuneration based on the volume of business placed with that insurer, the profitability of that business, or both. These arrangements create a structural conflict of interest: a broker who receives higher payments for placing more business with a particular insurer has a financial incentive to favour that insurer, even if another insurer's product would better serve the client.

The proposed ban on contingent remuneration when acting on a client's behalf is a significant step toward eliminating this conflict. However, it is important to note that the 2026 draft code has faced some pushback from NIBA regarding the prescriptive nature of certain requirements, and the final version of the Code may differ from the draft. Clients should ask their broker directly whether they receive any form of contingent remuneration from insurers.

What This Means for Australian Businesses and Individuals

The 2026 IBCOP reforms have practical implications for anyone who uses an insurance broker:

• Greater transparency at renewal — You will receive clearer information about what your broker is being paid, in dollar terms, before you commit to renewing your policy.
• More time to review — The 28-day pre-renewal contact requirement gives you more time to compare options and ask questions before your policy automatically renews.
• Reduced conflicts of interest — If the contingent remuneration ban is adopted in the final Code, your broker's recommendations should be less influenced by insurer volume incentives.
• Strata owners benefit — If you are part of an owners corporation, you will now receive direct disclosure of broker remuneration on strata insurance, rather than relying on your strata manager to pass this information on.

Australian Regulatory Context: ASIC, the Corporations Act, and AFCA

Insurance brokers in Australia operate under a dual regulatory framework. They must hold an Australian Financial Services (AFS) licence issued by ASIC and comply with the obligations of the Corporations Act 2001, including the requirement to manage conflicts of interest and act efficiently, honestly, and fairly.

ASIC's Regulatory Guide 181 provides detailed guidance on how AFS licensees should identify, manage, and disclose conflicts of interest. The 2026 IBCOP reforms are designed to bring broker conduct standards into closer alignment with this guidance.

In addition to ASIC oversight, insurance brokers are subject to:

• The Insurance Contracts Act 1984 — Which governs the terms of insurance contracts and the rights of policyholders, including the reformed duty of disclosure for consumer insurance contracts.
• APRA's CPS 230 — Which requires insurers to manage operational risks and oversee material service providers, including brokers who place significant volumes of business.
• The General Insurance Code of Practice — Which sets standards for insurer conduct and is separate from the IBCOP that governs broker conduct.
• AFCA — The Australian Financial Complaints Authority provides free dispute resolution for consumers and small businesses who have complaints about their insurance broker or insurer.

It is worth noting that the CRK review recommended making the IBCOP contractually enforceable — meaning that a breach of the Code would give clients a direct legal right of action against the broker. NIBA has expressed reservations about this recommendation, and the final position on enforceability will be an important factor to watch as the Code is finalised.

Common Mistakes When Choosing an Insurance Broker

Even with improved disclosure requirements, clients can still make costly mistakes when selecting and working with an insurance broker. Watch out for these common pitfalls:

• Choosing based on premium alone — The cheapest premium is not always the best outcome. A broker who genuinely understands your risk profile may recommend a slightly higher premium with significantly better coverage terms.
• Not asking about remuneration — Even before the new Code takes effect, you have the right to ask your broker how they are remunerated. A transparent broker will answer this question clearly and without hesitation.
• Assuming all brokers have access to the same insurers — Different brokers have different insurer panels. A broker with a limited panel may not be able to access the most competitive or appropriate product for your needs.
• Failing to review coverage at renewal — Many clients simply renew their existing policy without reviewing whether the coverage still meets their needs. The 28-day pre-renewal contact requirement is designed to address this, but you should proactively engage with your broker at renewal time.
• Not verifying ASIC registration — Always check that your broker holds a current AFS licence or is an authorised representative of a licensee. You can verify this on ASIC's Financial Services Register.

Questions to Ask Your Insurance Broker

When engaging an insurance broker — whether for the first time or at renewal — these questions will help you assess their transparency and suitability:

1. What is the exact dollar amount of your remuneration for placing this policy, and does this include any contingent or volume-based payments from the insurer?
2. Which insurers are on your panel, and are there any insurers you do not have access to that might offer a better product for my needs?
3. How do you manage conflicts of interest when recommending a particular insurer or product?
4. Are you a subscriber to the NIBA Insurance Brokers Code of Practice, and how do you handle complaints?
5. What is your process for reviewing my coverage at renewal, and will you contact me at least 28 days before my policy renews?
6. If I have a claim, what support will you provide throughout the claims process?
7. Are you registered on the ASIC Financial Services Register, and can I verify your licence details?

How MyMoney® Can Help

The 2026 IBCOP reforms are a step in the right direction for transparency in the insurance broking industry, but the quality of advice and service you receive still depends on the individual broker you choose. Finding a broker who is genuinely committed to acting in your interests — not just meeting minimum disclosure requirements — requires careful selection.

MyMoney® connects Australian individuals and businesses with qualified, ASIC-registered insurance brokers who are committed to transparent remuneration practices and genuine client-first advice. Our marketplace makes it easy to compare brokers based on their specialisations, insurer panel access, and client feedback.

Post a Brief to describe your insurance needs and receive tailored proposals from qualified insurance brokers. Or Browse Insurance Brokers on our platform to find a professional whose expertise and approach match your requirements.

As the IBCOP reforms are finalised and implemented, staying informed about your rights and the obligations of your broker is the best way to ensure you receive the coverage and service you deserve.