Third-party ownership

Types of delegated authority this guidance is relevant to

• Binding authority agreements
• Coverholder appointment agreements
• Service company agreements
• Digital platform provider agreements

Lloyd’s requirements

Managing agents must understand who owns and controls delegated authority third parties and maintain sufficient oversight to identify, assess and manage financial crime, conflicts of interest and other risks associated with those arrangements.

As set out in Y4861, managing agents should undertake proportionate due diligence on the third-party and individuals who own, control, govern or direct the third-party, both at appointment and as part of ongoing oversight. The nature and extent of due diligence should reflect the nature, scale and risk of the arrangement.

Lloyd’s expectations of managing agents

Due diligence of ownership and control should enable the managing agent to identify relevant regulatory action, disqualification, financial crime concerns, conflicts of interest or significant litigation that may affect the suitability of the third-party or the delegated authority arrangement.

Where concerns are identified, the managing agent should assess their significance, document the basis on which it is satisfied that the arrangement remains appropriate and implement any necessary mitigating actions.

Managing agents should retain appropriate records of their due diligence and oversight and make them available to Lloyd’s upon request.

Managing agents should ensure accurate, consistent ownership information is held. Effective challenge should be applied where ownership records in Lloyd’s systems conflict across related entities.

Last reviewed 26/10/2026

Last updated 29/10/2026