FinTech UK Embedded Insurance Platform -- White-Label B2B

Embedded Insurance Architecture

B2B white-label: (1) partner onboarding (bank/lender API integration), (2) insurance eligibility rules engine, (3) quote generation (Lloyds coverholder binding authority API), (4) white-label offer UI (embedded in partner journey, partner branding), (5) bind and policy issuance (GOV.UK Notify confirmation).

SMCR

Named Senior Manager responsible for each distribution arrangement.

FCA ICOBS and IDD Compliance

• 1ICOBS 6.1 -- IPID before purchase,
• 2IDD demands-and-needs (customer confirms insurance meets needs before purchase),
• 314-day cooling off right to cancel,
• 4ICOBS 2.6 -- fair, clear, not misleading (offer must not exploit customer context),
• 5Consumer Duty suitability (home insurance at mortgage -- appropriate; payment protection at cash machine -- not appropriate). Demands-and-needs questionnaire in every embedded journey.

PECR Consent Analysis

Insurance cross-sell at point of financial product: (1) if incidental to financial product (buildings insurance required for mortgage) -- PECR consent not required (legitimate interest), (2) if separate cross-sell (card protection added to credit card checkout) -- PECR explicit opt-in required.

Consent management

• clear opt-in, timestamp and IP recorded, withdrawal mechanism, audit trail for ICO defence.
• White-

Label Partner Portal

8 distribution partners each with own configuration: branding, product selection, performance dashboard (conversion, claims, partner revenue), pseudonymised customer data, FCA ICOBS quarterly compliance reports.

Revenue sharing

per-policy commission.

SMCR accountability

portal access restricted to certified individuals only.