For most people a call with a health insurance broker costs nothing, because the broker is normally paid by the insurer rather than billed to you. Normally is not always: the FCA's rules also let a broker charge a fee, so "free" holds for you only if the firm tells you it works that way. Weighing up whether to buy private medical cover through a broker? The short form on this page gets an FCA-authorised broker to phone you, free of charge, and the questions further down are worth putting to them when they do.
Free to you does not mean unpaid: the four ways a broker can be paid
Whoever you deal with, the FCA Handbook's Insurance: Conduct of Business sourcebook (ICOBS) makes the broker say how it is rewarded before you commit. Rule ICOBS 4.3.-7R (section last updated 1 October 2018, read 26 October 2026) requires an insurance intermediary to tell the customer "the nature of the remuneration received in relation to the contract of insurance", and to say which of four bases it works on:
- a fee, meaning money paid directly by the customer;
- "a commission of any kind, that is the remuneration included in the premium";
- any other type of remuneration, including an economic benefit of any kind offered or given in connection with the contract; or
- a combination of those.
The page on how health insurance brokers get paid goes through the pay rules one by one, and what a broker costs you in practice looks at the sums.
That list is the whole answer to the question in the title. If the firm is paid by commission alone, you are not invoiced, but the commission is part of what the premium pays for. If it charges a fee, you are the one paying it. A combination is allowed too. Because the rule requires the firm to say which basis applies before the contract is concluded, you can find out without having to guess.
What a broker has to tell you before you buy
Pay is one item on a longer list. ICOBS 4.1 (last updated 26 June 2026, read 26 October 2026) sets out what an intermediary must tell you in good time before an initial contract is concluded. This is the part of the rulebook that lets you check a broker's status before you commit to a policy. Under ICOBS 4.1.2R, the firm must tell you:
- its identity and address, and whether it is an intermediary or an insurer;
- whether it gives a personal recommendation about the products it offers;
- how to complain to the firm and to the Financial Ombudsman Service;
- that it is on the Financial Services Register, and "the means for verifying this"; and
- "whether it is representing the customer or is acting for and on behalf of the insurer".
The last item is easy to skim past and matters most. A firm that represents you and a firm acting for an insurer can both be called a broker or an adviser in everyday speech; the rule makes the firm say which it is.
A second rule, ICOBS 4.1.6R, covers whose products the firm sells. An intermediary that proposes or advises on a policy must say whether it gives a personal recommendation "on the basis of a fair and personal analysis"; whether it is contractually bound to deal exclusively with one or more insurers, in which case it must name them; or whether it is neither, in which case it must name the insurers it may and does do business with. Each of those three answers describes a different kind of firm, and you are entitled to know which you are talking to. The length of the insurer list is a fact about the firm, not a quality mark, so ask for it rather than assuming it.
Using a broker or buying direct: what the rules treat the same, and what differs
Buying direct from an insurer is a perfectly ordinary route, and nothing in the rules makes a broker compulsory. The differences are narrower than broker marketing suggests, and a few of the protections are the same either way.
| Question | Broker (insurance intermediary) | Insurer selling direct |
|---|---|---|
| Must it explain how its people are rewarded? | Yes. Under ICOBS 4.3.-7R, the nature of the remuneration: fee, commission, other, or a mix. | Yes, in a different form. ICOBS 4.3.-6R requires an insurer to give "information on the nature of the remuneration received by its employees in relation to the contract of insurance". |
| Must it check the policy fits what you need? | Yes. ICOBS 5.2.2D: "The sale of a contract of insurance must always be accompanied by a demands and needs test on the basis of information obtained from the customer." | Yes. ICOBS 5.2 applies to any insurance distributor, an insurer selling its own policies included, and ICOBS 5.2.2C says the duty to propose only a policy consistent with your demands and needs (ICOBS 5.2.2BR) applies "whether or not advice is given". |
| Whose side is it on? | It must say whether it represents you or acts for the insurer (ICOBS 4.1.2R). | It is the insurer, so it sells its own policies. |
| How many insurers can it talk about? | It must say which insurers it works with, or whether it is tied to some (ICOBS 4.1.6R). | One. |
The practical difference for a reader is therefore the last row. A broker that deals with several insurers can describe more than one in a single conversation, which a direct sale cannot. Whether that produces a better fit or a better price for you is not something any rule promises, and no rule makes either route the cheaper one.
What happens to broker pay if you cancel
This is where "free" is tested, because the commission or fee is no longer hidden in a premium you are happily paying. Under ICOBS 7.1.1R (section last updated 1 January 2016, read 26 October 2026), a consumer "has a right to cancel, without penalty and without giving any reason", within 30 days for a contract that is or includes pure protection, and within 14 days for any other contract of insurance. Under ICOBS 7.1.5R the period runs from the day the contract is concluded (for pure protection, from when you are told it has been concluded), or from the day you receive the contract terms and the other required pre-contract information, if that is later. Which of the two periods governs your own policy is written into the paperwork you receive, and a broker can show you where on a free call-back.
What you can then be asked to pay is set by ICOBS 7.2 (last updated 1 April 2013, read 26 October 2026). ICOBS 7.2.2R says you may only be required to pay for the service actually provided, and the amount must not be one that "could be construed as a penalty". The guidance at ICOBS 7.2.3G then lists what the amount may include, and two of its four items are the broker's: "a proportion of the commission paid to an insurance intermediary sufficient to cover its costs", and a proportion of any fee the intermediary charged, which together with any commission to be repaid would be enough to cover its costs.
The other two items are the sums the firm reasonably incurred in concluding the contract, without any element of profit, and an amount for the cover already provided. ICOBS 7.2.5G adds that the insurer and intermediary should take reasonable steps to avoid recovering selling costs twice, particularly where commission and fees are both recouped. In plain terms, a broker can be allowed to keep part of its pay for work already done, but not to collect the same cost twice, and under ICOBS 7.2.2R(3) a firm cannot require a payment unless it can prove you were told the amount.
Cancelling once the cancellation period has ended, or changing the policy part-way through the year, is a separate matter. Any payment you make under the contract after it starts, other than ongoing premiums and scheduled payments, brings the pay disclosure duty back (ICOBS 4.3.-2R), and the guidance names "mid-term adjustments, administration fees and cancellation fees" as examples. The cancellation wording in your policy documents shows what was agreed, and the page on how pay is disclosed covers those rules.
Seven questions for the call-back, each with the rule behind it
Each question below has a rule behind it, so the broker has to be able to answer it. Take notes on what you hear and compare it with the written terms you are sent.
- Will I pay you anything on top of the premium, and if so how much? ICOBS 4.3.-7R makes the firm say whether it works for a fee, a commission or both. Where a fee applies, ICOBS 4.3.1R requires the amount, or the basis for working it out, before you take on any liability to pay it.
- Do you represent me, or act for the insurer? ICOBS 4.1.2R requires the answer. If the firm sounds vague, ask it to say so in writing.
- Which insurers do you deal with, and are you tied to any of them? This is ICOBS 4.1.6R. Ask for the names so you know what the conversation can and cannot cover.
- Are you giving me a personal recommendation, or information only? The firm has to say which (ICOBS 4.1.2R), and under ICOBS 4.1.7R a firm that is tied to named insurers, or that gives no personal recommendation on a fair and personal analysis, must also tell a consumer whether it is giving a recommendation, other advice, or "just information".
- Can I see the statement of my demands and needs before I agree to anything? The rule requires a statement of your demands and needs to reach you before the contract is concluded (ICOBS 5.2.2R(3)).
- What would I owe you, and what would the insurer keep, if I cancelled within the cancellation period, or after it? ICOBS 7.2.3G shows why the answer can include part of the broker's commission or fee.
- What is your registered name, and where do I check you on the Financial Services Register? The firm must give you the means of verifying its entry.
Run through these with whoever calls you back. The call costs you nothing, and how clearly a firm answers tells you something about how it will deal with you later.
Needing a broker, finding one, and how it picks insurers
Do I need a health insurance broker to buy private cover?
No. You can buy from an insurer directly, as the comparison above shows, and the same demands-and-needs rule applies either way. A broker is one route, useful if you want several insurers described in one conversation; the broker, agent and direct comparison sets the three out side by side.
How do I get a health insurance broker?
Ask one to call you, find a firm yourself, or let the form on this page arrange a ring-round from one. Whichever you choose, ask for its Financial Services Register entry, which the firm is required to tell you how to check. For what a broker does and how to choose between firms, see the health insurance agency guide.
Are health insurance agents free too?
On cost, the same test applies: whether you pay anything depends on the pay basis the firm discloses under ICOBS 4.3.-7R. Where the label can matter is loyalty. Every intermediary must tell you whether it represents you or acts for the insurer (ICOBS 4.1.2R), and one tied to particular insurers must name them (ICOBS 4.1.6R), so an agent tied to a single insurer has to tell you which.
If a broker is paid by the insurers, how does it choose which ones to offer?
Not wholly as it pleases. Where a firm advises on a fair analysis of the market, FCA guidance at ICOBS 4.1.8G says one way to do that is a panel of insurers that is reviewed regularly, and that panel selection should rest on product features, premiums and service to customers, not solely on the benefit to the firm. A firm that is tied to particular insurers, or that gives no personal recommendation on a fair and personal analysis, must instead name the insurers it deals with (ICOBS 4.1.6R). Either way, asking how the list was chosen is a fair question.
Does a broker have to be on the FCA register?
ICOBS 4.1.2R requires an intermediary to tell you that it is on the Financial Services Register (or, if it is not, which register it is on) and how you can verify that. Look the firm up under the name it gives you before you pass on health details, and keep the reference number with your notes.