Conduct and culture

Issues related to conduct are covered mainly by ICP 18 (Intermediaries) and ICP 19 (Conduct of business) as well as a number of Issues Papers and Application Papers.

In July 2025, the IAIS published an Application Paper on fair treatment of a wide range of consumers. It focuses on the critical role that insurers, intermediaries and supervisors can all play through implementation of ICP 19 (Conduct of Business) to remove barriers and ensure that a wide range of consumers―not only those who fit within a more normative or mainstream customer profile―have access to the insurance products they need to protect themselves from risk of loss and are treated fairly in their interactions with the insurance sector. 

Recognising that traditional compliance-based approaches to conduct supervision have limitations, supervisors are increasingly looking to adopt more forward looking and outcomes-based approaches to conduct risk. In June 2022 the IAIS published a report on Supervisors’ use of key indicators to assess insurer conduct. The report presents findings from a survey of IAIS members on supervisory approaches and challenges related to using data and key indicators to assess conduct-related outcomes.

In follow-up, in 2023 the IAIS released a comprehensive member-only resource with more details on the types of indicators and data gathering techniques used by supervisors to assess the conduct of insurers. The resource, Use of conduct indicators in insurance supervision – approach and examples, features many examples and case studies. Member-only materials can be shared with all employees of an IAIS member organisation.

Roles and responsibilities for setting the cultural tone of the insurer, as well as for the practical embedment of this tone across the various levels and functional areas of the insurer, are described in the ICPs. Various ICPs make explicit reference to supervisory expectations regarding insurer culture, in particular ICP 7 (Corporate governance), ICP 8 (Risk management and internal controls) and 19 (Conduct of business). 

The IAIS also developed the Issues Paper on insurer culture, which explores the role of insurer culture as a point of intersection for managing prudential and conduct risks. The paper also provides illustrations of selected cultural drivers using jurisdictional examples. 

There are also interlinkages between insurer culture and the aspects of Diversity, Equity and Inclusion (DEI). Learn more about the IAIS’ work on DEI here.