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Your attention is drawn to the Solicitors Financial Services Regulations 2018 (the Regulations) which repeal the Solicitors Financial Services Regulations 2012 as amended and are in force since 01 July 2018.

These Regulations apply to solicitors who act as Ancillary Insurance Intermediaries when for example they arrange insurance such as title indemnity insurance or ‘after the event’ legal expenses insurance on behalf of a client, for remuneration, which is incidental or ancillary to the professional legal services they provide to that client. This is ‘regulated activity’.

As a Designated Professional Body under the Financial Services and Markets Act 2000, the Law Society must make regulations to govern such ‘regulated activities’ carried on by solicitors in Northern Ireland.

The Regulations, which have been approved by the Financial Conduct Authority, are designed to secure that, in providing a particular professional service to a particular client, the solicitor carries on only regulated activities which arise out of or are complementary to the provision by the solicitor of that service to that client.

The Regulations are available at the bottom of this page.

The Regulations implement the Insurance Distribution Directive (2016/97/EU), (the Directive) which aims to enhance consumer confidence when buying insurance products. The Directive defines an Ancillary Insurance Intermediary as any natural or legal person who, for remuneration, takes up or pursues the activity of insurance distribution on an ancillary basis. Insurance distribution activities are defined as the activities of advising on, proposing or carrying out other work preparatory to the conclusion of contracts of insurance, of concluding such contracts, or of assisting in the administration and performance of such contracts. Implementation of the Directive has been delayed to 01 October 2018.

A transitional period for compliance has been allowed so that the Law Society’s Financial Services Register will become operational on 01 October 2018 after which a firm must not carry on any insurance distribution activities unless the firm is included in the Law Society’s Financial Services Register as an Ancillary Insurance Intermediary.

Principals of firms must apply now to the Law Society for the inclusion in the Law Society’s Financial Services Register as an Ancillary Insurance Intermediary if your firm intends to provide the incidental or ancillary services to a client captured by the Regulations such as arranging insurance (for example title indemnity or ‘after the event’ legal expenses) on behalf of that client for remuneration.

Remuneration includes any commission from an insurance company or any fee paid by the client.

If you require an Application Form, please write to the Society or email your request to

The Law Society will notify you within three months from the receipt of a completed Application Form of the decision whether to include your firm in the Financial Services Register. Please note that the Law Society may be required to raise queries upon consideration of your Application Form, and an application form shall not be considered complete until such further queries have been concluded to the satisfaction of the Law Society.

The Law Society will issue an Application Form to every principal solicitor in all firms to ensure that principals are aware and put on notice of the requirements under the Regulations. The Law Society requires only one Application Form to be submitted on behalf of each firm, with the Declaration completed and signed by one of or the sole principal solicitors in the firm.

If your firm provides such incidental services to a particular client, but does not receive any such remuneration for such activities and includes a written statement to this effect in each relevant terms of engagement letter to the particular client, then the solicitor does not need to be included in the Law Society’s Financial Services Register as an Ancillary Insurance Intermediary.


The Society has been asked by the Financial Services Authority (the FSA) to amend the reference in Regulation 15.1(a) in the above to reflect a change in the FSA register home web address from to

The Lord Chief Justice has confirmed that this regulatory change may be notified to you by way of a note, rather than requiring a formal amendment to the Regulations.

We are taking the opportunity to republish the Financial Services Regulations 2004 and attached Guidances, in full, below. The Regulations have been amended to show the change at Regulation 15.1(a).

This affects the mode of access to the Insurance Mediation Register maintained by the FSA and described in the Guidances.


We would also take the opportunity to remind you that the workload of the Financial Services Committee has expanded significantly in the last number of years, to take account of the increasing demands of our co-regulators, not only the FSA, but also the Office of Fair Trading in relation to Consumer Credit Act business, for which the Society holds a Group Licence; with the Insolvency Service, for the regulation of Solicitor Insolvency Practitioners; and in relation to Anti-Money Laundering procedures, in relation which the Society has obligations to report to HM Treasury.

The Committee is actively exploring the development of insolvency related business for Solicitors, not only as Insolvency Practitioners, but generally, and to this end is directing CPD in relation to the Consumer Credit Act and insolvency matters, addressing the needs of both creditors and debtors. With the Professional Ethics and Guidance Committee the Committee also promotes CPD in respect of Anti-Money Laundering.


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