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How to Identify a Client’s Protection Needs with a Fact-Find

A client-centred fact-find starts with financial responsibilities and priorities, checks existing provision, and tests proposed cover against the client’s needs, budget, and policy terms.
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A fact-find helps a UK adviser identify what a client wants to protect, who relies on their finances, and what cover they already have before discussing insurance. Start with the client’s responsibilities and priorities—not with a product. Then assess whether any proposed cover fits those needs, is affordable, and provides meaningful protection under its actual terms.

Start with the client’s priorities and responsibilities

Ask what the client most wants to protect: their dependants’ financial security, housing costs, other debts, or their own income if illness or injury prevents them from working. MoneyHelper suggests considering responsibilities such as providing for children, covering housing payments, and maintaining income (MoneyHelper’s protection insurance guide).

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Useful opening questions include:

  • Who depends on you financially now, and might that change?
  • What financial responsibilities or future plans matter most to you?
  • What would be hardest for you or your household to manage if you died, became seriously ill, or could not work?
  • What do you most need to protect?

These questions establish the client’s objectives; they do not imply that every person needs every type of policy.

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Build a practical picture of household finances

Record the figures and commitments needed to understand the potential impact of an insured event. Relevant information may include take-home pay, essential living costs, debt repayments, and mortgage or rent costs. The purpose is to understand the client’s circumstances and possible protection gap, not to apply a universal coverage formula.

  • Income and the household’s reliance on it
  • Essential spending and regular commitments
  • Mortgage, rent, and other debts
  • Dependants and foreseeable changes in responsibilities

Account for cover the client already has

Before considering additional cover, establish what protection is already in place. Ask about personal policies, workplace benefits such as life cover or sick pay, and relevant packaged current-account benefits. Record what each benefit covers and any applicable amount, duration, eligibility requirements, or conditions. Existing cover can reduce a gap, but its presence alone does not show that it is sufficient for the client’s objectives.

For advised pure protection, FCA guidance says firms should use information readily available to them and obtain further relevant customer information, including information about existing cover. See FCA Handbook, ICOBS 5.3.

Match the need to the event each product covers

Discuss products in terms of the financial event the client wants to address. The broad distinctions below do not replace checking the wording and limits of a particular policy.

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Cover type Event it broadly addresses Fact-find focus
Life insurance Death or, under relevant policies, terminal illness; it may support dependants or a financial objective such as mortgage protection. Who would need financial support or what liability or objective the payment is intended to address.
Critical illness cover A lump sum if the insured person is diagnosed with a serious illness specified in the policy. Whether the covered-condition definitions and exclusions relate to the client’s concern and objective.
Income protection Regular payments when illness or injury prevents the insured person from working, subject to policy terms. How the client would manage income disruption and how the policy’s terms affect that support.

Life insurance does not replace income lost because the insured person is ill or disabled. Critical illness cover is tied to specified conditions and their policy definitions; income protection addresses inability to work due to illness or injury. MoneyHelper explains the broad product purposes in its guide to protection insurance; the FCA’s pure protection market study also describes these products.

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Test whether proposed cover fits the need

A product name or headline benefit is not enough to establish suitability. Consider the proposed level and duration of cover alongside its cost and the client’s finances. Review relevant exclusions, excesses, limitations, conditions, and eligibility requirements; explain what the client should understand about the cover. A policy only addresses the client’s objective to the extent its terms and benefit fit that objective.

Affordability is part of the assessment. Explore what the client can afford and the consequences of trade-offs in amount, duration, or policy features. Do not describe a policy as meeting a need without considering its cost and relevant terms. FCA guidance identifies cover level, cost, exclusions, excesses, limitations, and conditions as matters to consider for advised pure protection (ICOBS 5.3).

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Explain the recommendation and any unmet need

When making a personal recommendation, give a personalised explanation of why the contract best meets the client’s demands and needs. If a relevant need remains unmet, say so clearly rather than implying the proposed policy provides complete protection. The fact-find and explanation should be proportionate to the client and the complexity of the product—not a fixed generic questionnaire.

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Under the FCA’s UK rules, a firm must specify the client’s demands and needs using information obtained from the client before concluding an insurance contract; the statement must be communicated before conclusion, and a proposed contract must be consistent with those demands and needs. The level of detail should reflect the contract’s complexity and the type of client. For advised pure protection, the FCA also sets out the consideration of relevant customer information and personalised explanations for recommendations in ICOBS 5.2 and ICOBS 5.3. Check the live Handbook for current requirements.

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Use market figures as context, not as a client test

FCA figures illustrate that protection needs may not be widely considered, but they cannot determine what an individual client needs. In findings published on 21 September 2026, the FCA said 59% of adults without a protection product had never considered their protection needs (FCA pure protection market study). The FCA’s January 2026 announcement said 58% of adults did not hold a pure protection product (FCA announcement). Separately, 45% of term-insurance holders surveyed said protecting their mortgage was important; that is a survey response, not an estimate of how many clients need mortgage cover (FCA market study).

Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.

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