Insurance Distribution in Ireland: Intermediaries, Registration and Conduct

In Ireland, insurance cannot be sold or advised on by just anyone. According to the Central Bank of Ireland, an insurance intermediary must be registered if it wants to carry out the activity of insurance distribution, and doing so without registration is an offence. This guide explains who counts as an insurance intermediary, how registration works, which conduct rules sit on top of it and what firms, including Dublin-based brokers and the staff who work for them, should check. For the day-to-day conduct angle, including claims and outcomes, see our separate guide to insurance conduct, claims, distribution and outcomes.

This post draws on the Central Bank's intermediary pages and on the European Union (Insurance Distribution) Regulations 2018 (S.I. No. 229 of 2018) as made and published on the Irish Statute Book. We did not check later amendments. It is general information, not legal advice. Rules are amended, so confirm the current text before relying on it.

What "insurance distribution" means

The 2018 Regulations define insurance distribution as advising on, proposing or preparing insurance contracts, concluding them, or assisting in their administration, including through comparison websites. Certain incidental activities, claims management and the mere provision of data are excluded. An insurance intermediary is described as a person, other than an insurer or its employees or an ancillary intermediary, who carries on insurance distribution for remuneration.

The Regulations also create other categories:

• Tied insurance intermediary: a person distributing non-competing products for one or more insurers or intermediaries, under their responsibility.
• Ancillary insurance intermediary: a person whose main professional activity is not insurance distribution and who distributes only certain insurance that complements a good or service. The Regulations set conditions and some exemptions, which we have not set out here.

The Central Bank's page also notes that registered intermediaries may carry out specified related activities, such as loss assessment and helping consumers with insurance claims.

Registration with the Central Bank

The Central Bank's page on insurance brokers and intermediaries says the Insurance Distribution Regulations, which it calls the IDR, came into force on 1 October 2018 and replaced the European Communities (Insurance Mediation) Regulations 2005. The Irish Statute Book text of the 2018 Regulations confirms the 1 October 2018 start and sets out the following in its registration provisions:

• Intermediaries resident or based in Ireland apply to the Central Bank's Insurance Distribution Register.
• Applications must disclose qualifying shareholders and close links, and show that these do not hinder supervision.
• The Central Bank decides applications, and registration can be reviewed, varied or withdrawn, with a right to make representations first.
• Insurers and intermediaries must use only registered intermediaries.
• Firms already registered under the 2005 Regulations continued to be registered.

The Central Bank must keep an electronic, publicly accessible register. For companies and partnerships, the register lists the managers responsible for distribution. The Central Bank page points readers to its registers site, where firms can be checked, and to separate pages on the authorisation process and on revocations. Application details, timelines and forms are on those pages, and we have not reproduced them.

Tied insurance intermediaries

The Central Bank page explains one notable change. Before the IDR, only insurance or reinsurance undertakings could appoint tied insurance intermediaries. Under the IDR, intermediaries may also appoint other intermediaries as tied insurance intermediaries. The page says that a tied intermediary may be appointed only if it is of good repute and has the necessary general, commercial and professional knowledge and competence, and that the appointing firm remains fully and unconditionally responsible for the tied intermediary's acts and omissions. Appointments may be made only after the Central Bank confirms the tied intermediary's registration in writing, and approved appointments are entered on the public register. The page directs firms to review the relevant regulation of the IDR and to take legal advice where necessary.

Knowledge, competence and good repute

The 2018 Regulations require distributors and relevant staff to have appropriate knowledge and ability, require intermediaries to demonstrate compliance with minimum knowledge requirements set out in a Schedule, and include a professional training or development requirement. The Schedule groups knowledge areas under non-life risks, insurance-based investment products and life risks. They include policy terms, relevant law, claims and complaints handling, assessing customer needs, the insurance market, business ethics and financial competency. The Regulations also set professional indemnity and client-money requirements. We have not quoted the numerical requirements, because they sit in the text of the Regulations and may have been amended; read the current text.

On good repute, the Regulations say distributors must ensure relevant staff have no serious financial or property-related criminal convictions and have not been bankrupt unless discharged. Staff not involved in distribution or management are exempt.

The Central Bank's page says the qualifications or experience required depend on the retail financial products the intermediary plans to offer, and that details are in the Minimum Competency section of its website. The Central Bank's qualifications page (which shows no date) lists recognised qualifications by retail category, including life assurance, pensions, personal and commercial general insurance and private medical insurance, and says other qualifications may be recognised under the Minimum Competency Code 2017. That page does not mention continuing professional development. Our guide to the Central Bank Minimum Competency Code and CPD covers that regime in more depth.

Fitness and probity

The Central Bank's Guidance on the Standards of Fitness and Probity (November 2025) explains that individuals in controlled function roles must be competent and capable, honest, ethical and acting with integrity, and financially sound. A regulated firm must not allow someone to perform a controlled function unless it is satisfied on reasonable grounds that the person complies with the standards and has agreed to comply. For pre-approval controlled functions, the Central Bank must approve the individual before appointment. The guidance refers to insurance or reinsurance mediation in connection with a controlled function category. Firms should check the current list of controlled functions and the guidance for how it applies to their structure.

Conduct rules for intermediaries

The 2018 Regulations include conduct provisions. These cover a general duty to act honestly, fairly and professionally in customers' best interests, rules on identifying the customer's demands and needs and proposing suitable contracts, a standardised Insurance Product Information Document for non-life products, product oversight and governance, and additional rules for insurance-based investment products such as conflicts of interest and suitability assessments. They also require intermediaries to give customers information such as identity and address, whether they give advice, complaints routes (including the Financial Services and Pensions Ombudsman), registration details, whom they represent and the type of remuneration.

The Consumer Protection Code 2025

The Central Bank's page on the Consumer Protection Code 2025 says the Code took effect on 24 March 2026 after a 12-month implementation period and has two parts, the Standards for Business Regulations 2025 and the Consumer Protection Regulations 2025. The Regulations were made on 24 March 2025 as S.I. No. 81 of 2025. Part 4 applies to insurance undertakings and insurance intermediaries, with scope varying by chapter. Headings include additional business requirements, premium handling through segregated client premium accounts, differential pricing for home and motor renewals, automatic renewals, product information, knowing the consumer and suitability, post-sale information, premium rebates and claims processing.

The Regulations apply some provisions only in part to certain entities, and one provision disapplies certain parts for insurance distributors and for distribution of insurance-based investment products. For that reason, a firm should confirm which chapters apply to it rather than assuming the whole of Part 4 does. Our guide to Consumer Protection Code staff training in Ireland looks at the training angle.

Enforcement

The Central Bank page says that carrying out insurance distribution without registration is an offence. The 2018 Regulations also give the Central Bank powers to impose administrative sanctions, which include monetary penalties and temporary bans on individuals holding managerial roles at insurance intermediaries or undertakings, and to withdraw an intermediary's registration for certain contraventions. We have not set out penalty amounts. Check the Regulations and the Central Bank's enforcement pages for the current position.

A practical approach for firms

• Confirm your status. Check whether you are an intermediary, a tied intermediary or an ancillary intermediary, and that the register entry matches what you do.
• Map your people to the requirements. Record, for each adviser, the retail products they deal in and the qualification or competence route they rely on.
• Keep evidence. File qualifications, fitness and probity checks, training records and customer information templates in one place.
• Review disclosures. Compare your initial customer information with the list in the Regulations.
• Re-check after changes. The Code, the Minimum Competency Code and the Regulations are updated from time to time.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Do I need to be registered to give insurance advice in Ireland?

According to the Central Bank, an insurance intermediary must be registered to carry out insurance distribution, and carrying out the activity without registration is an offence. Check the register and the Regulations for your own situation.

Where can I check whether an intermediary is registered?

The Central Bank page points to its registers site, which is where registrations are published. The 2018 Regulations require the Central Bank to keep a publicly accessible electronic register.

Can an intermediary appoint tied insurance intermediaries?

Yes, under the IDR as described by the Central Bank, intermediaries may appoint other intermediaries as tied insurance intermediaries, provided the conditions are met and the Central Bank has confirmed the tied intermediary's registration. The appointing firm stays responsible for the tied intermediary's acts and omissions.

Does the Consumer Protection Code apply to insurance intermediaries?

The Consumer Protection Regulations 2025 include a part on insurance that applies to insurance undertakings and intermediaries, with scope varying by chapter. Some provisions are disapplied or limited for certain activities, so check the chapters that apply to you.

Which qualifications count for the Minimum Competency Code?

The Central Bank's qualifications page lists recognised qualifications by retail product category. It says other qualifications may be recognised, so check the page and the Code itself.

In short: register before you distribute, keep the register entry accurate, meet the competence, fitness and probity expectations, apply the conduct rules and Code chapters that cover your activity, and re-check the Central Bank and Statute Book pages when anything changes.