IAIS: what the ICP 18 and ICP 19 standards require of insurance agents and brokers

The International Association of Insurance Supervisors (IAIS) brings together regulators from more than 200 jurisdictions accounting for 97% of global insurance premiums. Its Insurance Core Principles (ICP) serve as a globally recognised framework for supervision and a basis for assessing national regulatory systems. For agents and brokers, the key ones are ICP 18 "Intermediaries" and ICP 19 "Conduct of Business".

ICP 18: professionally and transparently

ICP 18 requires the supervisor to set and enforce requirements for the conduct of intermediaries so that they conduct business in a professional and transparent manner. The standards of the principle provide for:

• mandatory licensing of intermediaries operating in the jurisdiction;
• ongoing supervisory oversight of licensed intermediaries;
• an appropriate level of professional knowledge, experience, integrity and competence; an intermediary should deal only in products for which it has the necessary qualifications and should know the status of the insurers whose products it sells;
• appropriate corporate governance within intermediary firms themselves;
• rules for client accounts, including disclosure of at whose risk client money is held;
• the regulator's right to require measures where there is a material risk of violations or harm to clients' interests.

ICP 19: fair treatment throughout the cycle

ICP 19 applies to both insurers and intermediaries. Supervision should require fair treatment of customers both before a contract is concluded and until all obligations under it have been fulfilled. ICP 18 complements it with those aspects of supervision that concern intermediaries only.

IAIS work in 2024–2026

• Fair treatment of a diverse range of consumers. On 7 July 2025, following consultations in 2024, the IAIS published an Application Paper building on ICP 19. It recommends making fair treatment of different customer groups part of the culture of insurers and intermediaries throughout the product life cycle: in design, distribution, communications, advice, claims handling, complaints handling and product review. The right to risk-based pricing is preserved. The IAIS also links the paper to the topic of insurance protection gaps.
• Supervision of AI. In July 2025, an Application Paper on the supervision of artificial intelligence was released. It confirms that the existing ICPs on governance and conduct of business also apply to AI systems. The consultation version specifically stated that the expectations concern both insurers and intermediaries. The IAIS is also preparing a members-only report on agentic AI, which is planned for release in early 2027.
• Market monitoring. In its GIMAR report (December 2025), the IAIS analyses the use of AI by insurers and the development of cyber insurance.

Why emerging markets look to the ICPs

The ICPs provide a common language with the international supervisory community: national regulatory regimes are compared and assessed against them, and information exchange between regulators is built on them. For Kazakhstan, this is a practical matter. The Agency of the Republic of Kazakhstan for Regulation and Development of the Financial Market (ARDFM) is a member of the IAIS and since August 2023 has been a signatory to its Multilateral Memorandum of Understanding on Cooperation and Information Exchange.

For intermediaries, the conclusion is simple: requirements for qualifications, disclosure of information, handling of client money and fair treatment throughout the term of the contract are not a local peculiarity but an international norm. Companies that already build their processes in line with the logic of ICP 18 and ICP 19 will be better prepared for the further development of national regulation.