Thematic Review of the Distribution of Insurance-Based Investment Products – Key Findings from the 2026 Mystery Shopping Exercise

This thematic review signals heightened supervisory focus on how insurers, intermediaries, banks and wealth managers sell and advise on IBIPs. For compliance teams, the key message is that distribution practices will be tested against actual customer experiences, not just documented policies. Firms should expect scrutiny of suitability assessments, disclosure of costs and risks, management of conflicts and inducements, target market alignment, and the quality of oversight of tied agents and intermediaries.

The mystery shopping results likely reveal gaps between intended conduct and frontline behaviour, making it essential to review sales incentives, training, monitoring and remediation frameworks. Action needed: boards and senior management should treat the letter as a supervisory priority, conduct a gap analysis against the findings, and strengthen controls where weaknesses are identified. Firms should also assess whether their distribution arrangements deliver good customer outcomes and be prepared to evidence remedial action.

While no new rules are introduced, the letter sets clear expectations that may inform future supervisory activity. Smaller firms may face greater implementation burden, but all distributors of IBIPs should review their processes. The reputational and regulatory risks of inaction include supervisory intervention, customer redress and loss of market confidence.

Conversely, firms that act early can differentiate themselves through robust conduct frameworks and improved customer trust.