The Insurance Brokers Code Compliance Committee's 2025 Annual Data Report recorded 5,417 breaches of the Insurance Brokers Code of Practice affecting 14,842 clients - and the National Insurance Brokers Association has welcomed it as evidence of a maturing compliance culture across the Australian broking industry.
The headline figures tell a nuanced story. The proportion of brokers self-reporting breaches rose to 62% in 2025, up from 58% in 2024, while the number declaring zero breaches continued to decline. Complaints rose to 3,133 during the year. But the more telling finding may be what happened to the brokers who previously reported nothing: of the six that declared zero breaches in 2024, five subsequently recorded breaches in their 2025 submissions - suggesting shortcomings in internal detection rather than clean compliance records. The IBCCC has noted that even well-run businesses are likely to encounter minor process failures, delayed communications or incomplete documentation that qualify as code breaches.
Renewal timeframes remained the dominant area of non-compliance - a persistent finding that the IBCCC says has represented roughly half of all reported breaches since 2017, with renewal failures in 2024 alone resulting in more than $3.7 million in financial impact. Terms of Engagement breaches rose 65% from the prior year, while communication-related breaches fell 26% to 993.
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.
NIBA chief executive officer Richard Klipin said the report reinforced the broking profession's commitment to transparency under the self-regulatory model. "This report gives brokers a clear picture of where the profession is performing well, and where there is more work to do. The increase in breach reporting reflects firms taking their compliance obligations seriously, identifying issues, and acting on them. That is exactly the behaviour the self-regulatory model is designed to encourage," Klipin said.
The zero-breach data, however, raises a pointed question about whether self-reporting alone is sufficient to capture the full picture - a tension the independent review of the Code has addressed directly.
The data arrives against the backdrop of a broader reckoning over broker self-regulation. An independent review of the Insurance Brokers Code of Practice, conducted by Cameron Ralph Khoury and released in December, concluded the profession faced significant challenges to its reputation and its self-regulatory standing, and that NIBA must respond substantively in the next version of the Code.
In January, NIBA released its formal response to the review, accepting six of 14 recommendations - primarily those it said would strengthen client protections - while rejecting the remainder. The IBCCC has separately signalled planned reviews into communication standards and conflict management.
That the breach data is rising at the same moment the self-regulatory framework is under formal scrutiny is not incidental. Whether the increase in reporting reflects genuine cultural maturation or a compliance function still catching up with the scale of the problem is precisely the question the next version of the Code will need to answer.
