Why remuneration disclosure breaches increased 695% last year

Something significant happened in Australian insurance broking last year.

Remuneration disclosure breaches jumped from 42 to 334 cases according to the IBCCC’s 2024 Annual Data Report. That’s a 695% increase. In one year.

This is a massive shift in how regulatory compliance is being measured and enforced.

Why remuneration disclosure matters

Remuneration disclosure exists to protect consumers from conflicts of interest. When clients understand how you’re paid, they can make informed decisions about your advice.

The regulation is clear. You must disclose all commissions, fees, and non-monetary benefits you receive or expect to receive at the same time as your advice or quotation.

In writing or verbally, as appropriate. With notes or records showing the disclosure was provided and steps taken to ensure the client understood it.

Where brokers are getting caught out

The spike in breach reports reveals common patterns:

Incomplete disclosure. Mentioning commission but not stating the actual percentage or dollar amount. Disclosing some fees but not all of them. Forgetting to mention volume-based incentives or aggregator benefits.

Timing failures. Providing disclosure after the placement, not at the same time as the advice. Sending it in a follow-up email rather than in the initial quotation. Making verbal disclosure but failing to document it.

Lack of proof. No record that disclosure was provided. No documentation showing the client understood the information. File notes created retrospectively when a complaint arrives.

The NIBA reality check

NIBA’s Ready or Reacting report shows 86% of Australian brokers anticipate increased regulation by 2035. The remuneration disclosure spike suggests that future is arriving faster than expected.

Only 62% of brokers feel their business is prepared for increased regulatory scrutiny. Based on the breach numbers, that confidence might be misplaced.

What changes the game

Confidence in remuneration disclosure audits starts with systems that:

1. Trigger disclosure automatically. When a quote is generated, remuneration disclosure is included by default. No manual process. No relying on someone to remember.
   
2. Log and track everything. Every disclosure is recorded with timestamps showing when it was sent, whether it was opened, and when the client acknowledged it.
   
3. Create immutable records. Once created, the disclosure record is locked. No editing, no deleting, no convenient updates when scrutiny arrives.
   
4. Link to the client file. Disclosure documentation sits alongside policy records, advice notes, and authority to proceed. Everything connected, everything accessible.

The principle is simple: If you can’t show it, you can’t prove it.

The 695% spike in remuneration disclosure breaches isn’t going away. Regulatory expectations are tightening. Documentation standards are rising.

The good news? Modern document management and productivity tools purpose-built for brokers can close these gaps before the next audit.