Renewal timeframe failures accounted for nearly half of all code breaches in 2025, as the Insurance Brokers Code Compliance Committee (IBCCC) called on brokers to examine whether their internal systems are identifying and reporting issues as they arise.
The IBCCC released its 2025 Annual Data Report on June 16, documenting 5,417 breaches of the Insurance Brokers Code of Practice across the year. Those breaches affected 14,842 clients, while complaints rose from the prior year to reach 3,133 – meaning both breach volumes and complaint volumes increased in the same reporting period. The findings point to recurring weaknesses in the systems brokers use to manage client engagement, disclosure, and oversight.
Three compliance areas drove the bulk of the findings: renewal timeframe obligations, client communication quality, and Terms of Engagement disclosures. Of those, Terms of Engagement breaches recorded the sharpest movement – rising 65% from 2024 – pointing to weaknesses in broker onboarding and disclosure practices. The figures may also understate the problem: five out of six brokers that declared zero breaches in 2024 subsequently recorded breaches in 2025, indicating gaps in internal detection and reporting systems across the industry.
Brokers reported 480 Terms of Engagement breaches in 2025 – up 65% from 291 the prior year – making up 9% of all code breaches and affecting 582 clients. The IBCCC noted no direct financial impact was reported but said the failures indicate increasing risk to informed client decision-making. File-level reviews found documentation that was missing, out of date, or non-compliant. Recurring gaps included inadequate disclosure of conflicts of interest, remuneration, the broker’s role or capacity, and references to the code itself.
These requirements take on greater significance where brokers are not acting solely on behalf of the client – for example, under underwriting agency agreements or when exercising claims settlement authority on an insurer’s behalf. In those arrangements, clients who are not informed at the outset may assume a level of representation the broker is not positioned to provide. Absent or incomplete documentation reduces client visibility over fees, roles, and rights, increasing the likelihood of disputes and formal complaints. Section 4.2(a) of the code requires brokers to provide clients with written Terms of Engagement containing prescribed information before services are provided. Those onboarding and disclosure weaknesses are compounded by the process failures that follow, with renewal timeframe breaches continuing to generate the highest volume of non-compliance across the industry.
Renewal-related failures rose 10% in 2025, accounting for close to half of all breaches. Of brokers that reported any breach, 75% – 174 brokers – recorded at least one renewal failure, including 180 breaches graded at severity level three or above, indicating serious and escalating risk to business operations. Brokers recorded 2,077 breaches for failing to contact clients at least 14 days before policy expiry, affecting 7,854 clients, with a self-reported financial impact of $157,600.
A further 603 breaches related to failures to seek cover and advise clients of available options, affecting 1,025 clients. The self-reported financial impact in this stream was $2.17 million – roughly 14 times that of the first stream despite less than a third of the breach volume, a disparity that points to the relative severity of failures to advise clients compared to late contact alone. Brokers cited contributing factors including failure to follow renewal procedures, manual error, system limitations, and resourcing pressures during peak periods or staff transitions.
The IBCCC noted that while most breaches did not result in uncovered periods, some clients experienced gaps in cover or significant risk exposure. IBCCC chair Oscar Shub said the consequences for clients were direct. “Clients need enough time before renewal to consider their options, understand any changes to their cover, and make informed decisions about the protection they need. When renewal processes are not working properly, clients can be left with uncertainty, reduced choice and, in some cases, real exposure to risk,” Shub said.
Communication-related breaches fell 26% overall to 993, representing 18% of all code breaches. Within that category, breaches for failure to ensure clients understood the advice they received rose 69% – from 5% to 9% of all breaches – affecting 794 clients and carrying a self-reported financial impact of $1.04 million. Breaches tied to timely and clear communication fell from 19% to 10% of all breaches, affecting 543 clients.
The IBCCC said brokers frequently uncovered these failures through file audits, where key details – including exclusions, fee structures, and changes to cover – had not been adequately explained or confirmed as understood. In several cases the gap only became apparent at claim time, increasing both financial exposure and the likelihood of a formal complaint. Shub said the issue extends beyond the mechanics of information delivery. “Clear advice is central to good broking practice. It is not enough for information to be provided. Clients need to understand the advice they are receiving, the role their broker is playing, and what the recommended cover means for them,” Shub said.
The IBCCC said brokers reporting zero breaches and zero complaints should not treat that outcome as confirmation of full compliance. The committee said that in practice, even well-run businesses are likely to identify issues from time to time – including minor process failures, delayed communications, and incomplete documentation – that may amount to a code breach or generate an expression of client dissatisfaction. Its focus, it said, is not on whether brokers make errors but on whether their systems are equipped to detect, escalate, and record them when they occur. Of six brokers that declared zero breaches in 2024, five subsequently recorded breaches in their 2025 submissions – indicating issues existed but had not been detected internally.
“Good compliance is not shown by simply reporting nothing. Brokers should have systems that actively identify issues, including minor process failures, delayed communications, and incomplete documentation. Self-identifying and addressing problems is a sign of a more mature compliance framework,” Shub said. The IBCCC said it would continue to prioritise reviews of brokers submitting zero returns, focusing on firms with more than 30 full-time equivalent staff, and may take further steps to independently test compliance framework effectiveness through targeted inquiries. The 2024 follow-up activity showed that approach can surface issues that internal systems had not detected.
