1 Obligations under the regulations
There is no single FCA “gift limit”. The obligation is to stop gifts, hospitality and other benefits from distorting advice, placement or claims decisions, and to be able to show that.
Firms carrying on insurance distribution must keep a gifts and benefits policy that states clearly when gifts and benefits may be accepted or granted, and the steps to take when they are. ICOBS 2.3 treats inducements widely: cash, cash equivalents, commission, goods, hospitality and training offered with a view to a particular course of action. Principle 8 still requires you to manage the conflict fairly. The Bribery Act 2010 makes it an offence to offer, promise or accept an advantage to induce or reward improper performance; commercial organisations are expected to have adequate procedures to prevent bribery.
Hospitality that is modest, recorded and consistent with your policy is not, by itself, a breach. Hospitality tied to a placement, a binder or a claim outcome needs a conflicts assessment — see conflicts of interest. Cash and cash equivalents are the cases most policies prohibit outright.
2 What do I need to do
Set the classes in the policy, then make every offer and receipt pass through one register before someone decides it was “only a lunch”.
1. Record the gift or hospitality when it is offered
Capture giver, receiver, organisation, date, description, estimated value, and whether it was offered, accepted, declined or returned. Include hospitality given as well as received. Regzact can assist: record each gift or hospitality item on the Gifts and Hospitality register as soon as it is declared.
2. Classify it against your policy
Typical classes are permitted within a threshold, permitted only with prior approval, or prohibited. Classify before the event where the policy requires pre-approval, not afterwards. Regzact can assist: classify the entry and route it to the approver your policy names.
3. Decide, and link it to a conflict if there is one
Approve, refuse or require the item to be returned. If the benefit could influence a placement, a claim or a supplier choice, raise a conflict and record how that risk was managed. Regzact can assist: store the decision, the approver and any linked conflict on the same record.
4. Report patterns, not only single items
A series of modest hospitality from one capacity provider can matter more than one expensive dinner. Report by person, counterparty and value so senior management can see accumulation. Regzact can assist: report and export the register for audit and board review.
3 What records do I need to keep
Adequate procedures under the Bribery Act, and the gifts and benefits policy under SYSC, both depend on a record you can produce. Keep refused and returned items as well as accepted ones.
- Giver, receiver, their organisations, and the date offered and the date of the event
- Description, estimated or actual value, and currency
- Classification: permitted, approval required, or prohibited
- The decision, who approved or refused it, and the date of that decision
- Whether the item was accepted, declined or returned
- Any link to a conflict, placement, claim or supplier decision
- Cumulative value by person and counterparty over the reporting period
Retain the register with your conflicts records. Five years is the SYSC benchmark for the conflicts record; match gifts that form part of that record to the same period.
4 Using AI to streamline the process
Approval stays with the person named in your policy. AI can help classification and pattern spotting:
- Suggest a class from the description and value, against rules you have set
- Flag cash, vouchers and hospitality close to a renewal or tender
- Total recent items from the same counterparty before an approver signs
- Draft the register entry from a short declaration
Do not let a model approve a gift. Use it to classify and total; keep the decision with the approver.
5 How Regzact can help
Regzact fully manages gifts and hospitality on the Gifts and Hospitality register: record what was given or received, classify it, and keep the approval with the entry.
- Capture of gifts and hospitality offered, accepted, declined or returned
- Classification against your policy and a recorded approval decision
- Links to the people and organisations involved, alongside the conflicts register
- Reporting and file export so accumulation is visible to audit and the board
Staff records and partner profiles sit on the same platform, so a declaration is not a side spreadsheet.
This is a practical how-to for compliance managers. It is not legal advice. Always check the current text of the regulations and your own policies before you act.