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For insurers operating across Europe, delegated authority enables broader distribution through managing general agents (MGA), but it does not transfer regulatory accountability. Insurers remain responsible for ensuring delegated activities comply with governance and regulatory requirements.
That responsibility became more complex following Brexit. The establishment of Lloyd’s Europe in Brussels exposed a knowledge gap between the London insurance market and Europe's country-specific regulatory landscape. Insurers must navigate differing governance, reporting and compliance requirements across jurisdictions, as an arrangement accepted in one country may not satisfy regulators in another.
Jack Knapen Consultancy bridges this gap by helping insurers strengthen oversight of delegated authority arrangements through country-specific compliance advisory, governance reviews and tailored audits. It also helps MGAs align governance frameworks, operating procedures and compliance obligations with local regulatory requirements.
“Europe is not one regulatory market,” says Jack Knapen, founder. “Effective oversight begins with understanding each jurisdiction.”
The firm's advisory approach is grounded in Knapen’s expertise, developed over more than four decades across underwriting, claims, delegated authority and executive leadership. He was involved with Lloyd’s Europe from its inception and is a certified compliance officer with firsthand knowledge of its regulatory framework. Through audit engagements across Europe, he has seen arrangements approved within the Lloyd’s of London market fall short of local regulatory requirements, creating compliance breaches that require corrective action.
Delivering Regulatory Readiness
Preventing such gaps requires a clear understanding of every jurisdiction involved. Each engagement therefore begins by identifying the regulatory requirements that apply across the insurer, MGA and policyholder jurisdictions. Jack Knapen Consultancy reviews binding authority agreements, governance frameworks and operating procedures against local regulatory expectations. This review is particularly important in complaint handling, where regulators expect country-specific dispute-resolution clauses, not only broad compliance statements.
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Europe is not one regulatory market. Effective oversight begins with understanding each jurisdiction.
For example, policyholders in Hungary may need to be informed about the Hungarian Financial Arbitration Board, those in the Netherlands about Kifid and those in Belgium about the Insurance Ombudsman.
Data reporting presents another common challenge. Under Solvency II, insurers must maintain detailed visibility into the risks written through delegated authority arrangements. Bordereau reports therefore need to capture risks written, insured values, risk locations, policyholders, coverage and deductibles.
Jack Knapen Consultancy frequently identifies incomplete, inaccurate or delayed submissions, recommends corrective actions and, where necessary, conducts follow-up audits six months or a year later to assess whether the required improvements have been implemented.
This risk-based approach extends across the consultancy's audit engagements. Standard audit scopes do not always capture every governance or compliance risk that emerges during fieldwork. Rather than treating audits as checklist exercises, Jack Knapen Consultancy expands the scope where appropriate, investigates additional risks and provides tailored recommendations that strengthen delegated authority oversight.
Building Stronger Delegated Authority Frameworks
Beyond advisory and audit engagements, Jack Knapen Consultancy supports MGAs seeking approval as Lloyd’s coverholders. It recently assisted an MGA in Lithuania and is now supporting a similar engagement in Hungary. The consultancy reviews governance frameworks, operational procedures and compliance arrangements against Lloyd’s minimum standards and relevant regulatory requirements. It helps address identified gaps and consolidates the required information into a business case for submission.
Maintaining that expertise requires continuous engagement with Europe's evolving regulatory landscape. Knapen participates in DARA, a London-based auditor association, and regularly exchanges knowledge with the wider audit community. He also recently trained the auditors and staff of a large audit firm on European regulatory requirements. These activities help clients stay ahead of country-specific regulatory developments that often receive less attention than UK regulatory changes. Knapen's long-term visio
Knapen's long-term vision is to strengthen delegated authority governance across Europe by expanding the consultancy's specialist advisory and audit capabilities. Combining regulatory advisory with risk-focused auditing, Jack Knapen Consultancy helps insurers and MGAs build governance frameworks that can adapt as jurisdiction-specific regulatory requirements continue to evolve.
Cross-Border Control for Delegated Insurance Networks
A binding authority can look complete on paper and still leave an insurer exposed across several European markets. The rules governing the arrangement may come from the insurer’s licensing jurisdiction, the intermediary’s home market and the country where the policyholder is based. For executives seeking insurance compliance consultancy, this makes local knowledge essential. Europe cannot be treated as a single regulatory environment, and a broad contractual obligation will not necessarily satisfy the expectations of every local supervisor. What matters is whether the control documents reflect how business is actually written in each market and whether the insurer can demonstrate that delegated activities are properly overseen.
Complaint handling is a good example of where local requirements can make a difference. A policyholder may need to take a complaint to a national dispute resolution body, but the binding authority may not explain how complaints should be routed in that market. The same issue can arise when procedures follow general market standards but have not been checked against local laws. An adviser must be able to translate these requirements into clear contractual clauses, practical procedures, reporting responsibilities and review processes that insurers and MGAs can put into practice. This requires more than familiarity with regulations. The adviser must understand how delegated authority operates day-to-day, including the underwriting powers granted to the MGA and each party's responsibilities for reporting and oversight.
Reporting is just as important. Insurers depend on bordereaux to keep track of the risks written under delegated authority and meet their Solvency II obligations. When reports arrive late or contain incomplete risk information, that oversight becomes harder. Even where reports are submitted on time, poorly defined data fields can leave important details unclear, including policyholder location, coverage terms, risk values and deductibles. Insurers should therefore look beyond whether a consultancy can spot reporting errors. They need an adviser who can identify where the reporting process is breaking down, establish what information must be captured and make clear who is responsible for correcting it. The advice should also explain how improvements will be checked.
“Jack Knapen Consultancy reviews procedures, reporting controls, contractual terms and business-case documentation, drawing on its knowledge of Lloyd’s Europe requirements and country-specific regulations.”
The same distinction applies to audits. A standard audit scope may confirm that the required documents are in place without showing whether the MGA's actual practices meet the insurer's expectations. A more useful review follows the evidence. If an initial finding points to a risk that has not been examined, the audit should go further rather than remain confined to its original checklist. It should also distinguish between identifying problems and putting them right. Findings need to lead to practical recommendations, with a clear process for management review and further testing where necessary.
For cross-border assignments, the depth of regional knowledge matters more than the size of the consultancy. An adviser needs to understand the requirements of individual national regulators as well as how Lloyd’s Europe expectations apply alongside local rules. It is also important to have support throughout the approval process, from reviewing procedures before submission to checking controls once authorization has been granted. At the end of the engagement, the insurer should have documents it can actually use and a clear way to monitor compliance, rather than a report that remains separate from its day-to-day work.
For insurers and MGAs managing delegated authority across Europe, Jack Knapen Consultancy is a strong choice. Its services include compliance consultancy, tailored coverholder audits, focused Quick Scans and coverholder application support. Drawing on its knowledge of Lloyd’s Europe requirements and country-specific regulations, the firm reviews procedures, reporting controls, contractual terms and business-case documentation. It also connects audit findings with corrective action, with scope for follow-up testing where required. For organisations dealing with differing national requirements or gaps in delegated-authority reporting, Jack Knapen Consultancy brings the regional knowledge and practical approach needed to strengthen oversight.
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