Everyone in insurance is talking about affordability. They are also talking about accessibility, and they are right to be talking about both. Premiums have risen hard, underinsurance is climbing and for too many households and businesses, cover that was once routine now takes real sacrifice.
Most of that conversation is about weather, reinsurance and claims inflation. Those forces are real, they are global, and they are slow to shift. There is another driver; it sits within our own control as a country and we talk about it far less. Every time you add regulatory complexity, someone pays. Usually, it is the client.
This is the second piece in a conversation NIBA started earlier this year. The first set out what a professional code is for, and the test the NIBA board applied to every obligation in the draft Insurance Brokers Code of Practice. Where a new requirement buys a better outcome for clients, it is worth paying for. Where it does not, the client funds a process that protects nobody. I want to be direct about where that test leads, because it does not stop at our code.
Getting a code right means holding three things together at once: what clients need, what regulators need, and what a profession needs in order to keep growing and serving. Lose any one of them and the other two fail with it. A code that ignores clients is not worth having. A code that ignores the cost of compliance quietly shrinks the number of people who can afford the service it governs.
That is why the board weighed simplification against complexity on every proposed change, rather than treating more obligations as automatically better ones. Every obligation a code adds is an obligation someone administers, documents, trains for and pays for. We were willing to pay it in several places and we said so. We were not willing to pay it everywhere.
The same discipline is missing from the wider regulatory conversation, and the absence is expensive.
There is no single response to rising compliance costs. Some absorb it and invest in systems. Some pass it on. Some narrow what they offer, or who they can afford to serve.
Our own research shows where the pressure sits. In Ready or Reacting? Shaping the Future of the Broking Profession, 86% of brokers expect regulatory demands to have a significant impact by 2035, while only 62% feel prepared. That is the widest gap of the eight forces we tested.
Picture a broker’s obligations as a house. The law is the floor, and every business in the country meets it. Licensing builds the walls, where regulators add to the law and test it through the licence. Our code is the storey above. A firm’s own standards are the roof. Every layer does the same job, which is to protect the client. Every layer also carries a cost, and those costs do not sit side by side. They stack. No client is billed by the layer. The client is billed for the whole house. And while the Insurance Council of Australia in late 2025 calculated annual compliance costs across the general insurance industry cost consumers $2.5 to $3.5 billion per year, no one prices the whole house, because each layer is designed in its own process, on its own merits, by people doing their job well.
NIBA recognises, in that context, that our code is the one layer this profession builds for itself. That is why we weighed what every obligation in it would buy a client before asking a client to fund it.
Complexity is not the enemy of broking. It is the reason clients come. In Complexity to Clarity: The Broker Advantage, 67% of businesses said they went to a broker because they were growing or their risks were becoming more complex, the most common reason given. That is the same complexity arriving from the other direction. It sends clients toward a broker. Regulatory complexity moves brokers away from clients.
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What sits at risk is measurable. The same research found clients save around 20 business hours; 94% improved their risk management on their broker's advice; 88% are confident their cover is right for their business; and 98% of claims are ultimately resolved. These are not abstractions. They are what a client keeps when they can reach a broker, and what they go without when they cannot. Clients can see the direction of travel: asked to look out to 2035, 56% expect fewer broking firms.
Recent government inquiries into natural disasters, into insurer conduct, and into business failures have circled back to the same finding. Consumers and businesses do better when they can reach a professional who understands the risk landscape and will advocate for them. That makes the cost of providing that service a public-interest question, not a trade one.
Insurance broking is not the first profession on this road. Financial advice is the closest example, and it is not the only one. The shape is familiar: successive waves of reform, each defensible on its own terms, compounding into a cost of doing business. None of those reforms set out to price a service beyond reach. Together, that is what they did, and repair has proved far harder than restraint would have been.
Brokers place $35.6 billion in premium each year with local general insurers, 46% of Australia's general insurance market, and the profession is deeply embedded in the communities it serves.
Affordability is not only a market outcome. Neither is accessibility. Weather we cannot legislate. Complexity we can.
That is the discipline behind the Code the board is now finalising. On every proposed obligation, we asked what it would cost, and whether a client would be better off for it. Where the evidence showed a new standard protects clients, the draft lifts the bar above the law.
Where it would have added a duplicate layer that clients ultimately fund, it does not. Affordability, accessibility and complexity were not side considerations in that process. They were the test.
NIBA will keep making that case to government and to regulators, because the alternative is a market where good advice becomes a luxury. Australian families, businesses and communities deserve better than to carry both the cost and the risk.
Richard Klipin is Chief Executive Officer of the National Insurance Brokers Association