New Zealand doesn’t have a specific licensing regime for MGAs. The regulatory framework for insurance intermediaries is relatively light-touch compared to European jurisdictions.

Entities operating as MGAs may need to register on the Financial Service Providers Register (FSPR) depending on the nature and scope of their activities. While there is no MGA-specific license, if the MGA provides “financial advice” – being advice, recommendations or opinions about acquiring or disposing of a policy or which type of cover to take out – then it may need to be licensed as a Financial Advice Provider (FAP), or be an “authorized body” of another FAP. A FAP license isn’t required if advice is only provided to wholesale clients but certain duties still apply.

If the MGA is transacting insurance business, binding the insurer, and possibly handling claims, but not providing financial advice, no FAP license is required. But the MGA may have to register on the FSPR if they’re providing a “client money or property service.” If financial advice is provided to retail clients, they will need to be registered on the FSPR.

If required, a FAP license will generally take 3-4 months to obtain.

New Zealand doesn’t participate in any passporting regime equivalent to the EEA framework. MGAs established in New Zealand must obtain separate authorizations or registrations in each jurisdiction where they wish to operate.

New Zealand doesn’t currently operate a specific insurtech regulatory sandbox. But the FMA has shown interest in supporting financial innovation and has engaged with the fintech sector. The relatively light-touch regulatory environment may itself provide a degree of flexibility for innovative business models.

If the MGA has to register on the FSPR as a financial service provider, then any controlling owners of the MGA must not be: an undischarged bankrupt; banned from being a director, promoter or manager of a company; convicted of financial crimes in the last five years; or categorized as displaying similar serious disqualifying characteristics.

New Zealand’s Financial Markets Conduct Act imposes conduct obligations on financial service providers, including requirements related to fair dealing and disclosure. While these don’t replicate the formal POG framework of the IDD, they require MGAs to maintain appropriate standards in their product design and distribution activities.

New Zealand doesn’t impose specific client money segregation rules on MGAs. The handling of premiums and claims funds is generally governed by the contractual arrangements between the MGA and the insurer, supplemented by the FMA’s general conduct obligations. If the MGA provides a “client money or property service,” certain obligations for handling the client money will apply.

New Zealand doesn’t impose minimum capital or professional indemnity insurance requirements specifically on MGAs. While PII coverage may be expected by insurer partners as a matter of commercial practice, there is no regulatory mandate. This contrasts significantly with the harmonized requirements in the EEA.

New Zealand’s light-touch regulatory regime offers low barriers to entry but limited regulatory structure for MGAs. The absence of specific MGA regulation, passporting rights, and mandatory capital or PII requirements means that MGAs must rely more heavily on contractual arrangements with their insurer partners. The jurisdiction is best suited for MGAs focused primarily on the New Zealand domestic market.