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Advised or non-advised

The short answer

Two firms can both arrange your group private medical insurance, both be regulated by the Financial Conduct Authority, and still offer very different services. One recommends a policy and gives you its reasons. The other shows you options and leaves the choice to you.

Three questions separate them. Will you advise us? Which insurers can you approach? Who holds your permissions? The answers are in the firm's terms of business and on the FCA register, and they take about five minutes to check.

No other firm described Last reviewed 27 September 2026

Advised and non-advised: the difference

Advised means the firm makes a personal recommendation: this policy, on these terms, for these reasons. It has to take reasonable care that the recommendation suits you, and if it does not, that is a failure you can complain about.

Non-advised means the firm gives you information and arranges what you choose. It still has to understand your demands and needs, and it must still be authorised or be an appointed representative, but the decision about whether a policy suits you is yours. A non-advised firm's terms usually say so plainly, with a sentence such as "you will not receive advice or a recommendation from us".

Watch the words used in sales material. "Guidance", "support", "our team will walk you through the options" and "compare quotes side by side" all describe help. None of them is a recommendation. The terms of business are what count.

Whole of market or a limited range

Alongside whether it advises, a firm must tell you on what basis it chooses insurers: a fair and personal analysis of the market, or a named set of insurers. A firm that does not recommend on the basis of a fair and personal analysis must give you the names of the insurers it deals with before you buy.

A limited range is not wrong in itself. It becomes a problem when the insurer that would suit your people best is not on the list, because nobody will tell you it was missing. For group PMI, ask for the list and compare it with the insurers you know write group cover in the UK.

Four arrangements, side by side

ArrangementRecommends a policyHow wide it looksWho decides suitability
Advised, whole of marketYes, with reasons in writingA fair analysis of the insurers writing that coverThe firm
Advised, limited rangeYes, with reasons in writingThe named insurers it works with, which it must give youThe firm, within that range
Non-advisedNoA named list of insurers, which it must give youYou
Direct from one insurerDepends on the insurerThat insurer's own productsUsually you

Appointed representatives: normal, and checkable

Many brokers and platforms do not hold FCA authorisation themselves. They are appointed representatives of a firm that does, called the principal, which takes regulatory responsibility for what they do. That is common and it is not a warning sign. Alltoogether is one.

What matters is the scope. The FCA register lists every appointed representative with its principal. The principal's permissions set the outer limit, and the representative's own terms of business tell you which of those services it actually offers you. Check both names: the firm you are speaking to and the principal behind it.

Why it matters most for group PMI

Group private medical insurance has more decisions inside it than most benefits, and several of them are hard to reverse once made.

  • Underwriting basis. Moratorium, full medical underwriting and medical history disregarded treat existing conditions very differently.
  • Switching insurer. Whether employees keep cover for conditions they already have depends on how the move is arranged.
  • Hospital lists, excess and outpatient limits. Each moves the price, and each changes what an employee can actually use.
  • Mental health cover. Limits and exclusions vary widely between policies and are easy to miss on a comparison grid.
  • If nobody is recommending, each of these is your call. That can be fine if you know the product well. It is a lot to carry if you do not.

If you also want an employee platform

Many employers want two things from one firm: advice on the cover, and somewhere employees can see what they have and how to use it. Those are separate questions, and a firm can be strong on one and not the other. Ask these alongside the advice questions.

  • Is the platform included, or charged on top? Some firms include it; others charge per employee per month. Get the answer in writing.
  • Whose software is it? Some firms build their own. Others put their brand on a platform licensed from a supplier. Neither is wrong, but it tells you who fixes problems and who decides what gets built next.
  • What does it actually do for an employee? Ask to see an employee find their cover, a policy document and how to claim, on a phone.
  • What happens if you change broker? Ask whether the platform, your data and your employees' access stay or go.

When non-advised is the right choice

If you already know exactly what cover you want, on what terms, and the only open question is price or administration, a non-advised service can do the job. Many employers buy that way on purpose.

The risk is buying non-advised without knowing it, and assuming someone has checked that the cover suits your people when nobody has.

The five-minute check, for any firm

Use these with every firm you speak to, including us.

  • Open the firm's terms of business and find the section on services. Does it say it advises, or that you will not receive a recommendation?
  • Find the sentence on market scope: fair analysis of the market, or a limited range. If limited, the firm should already have given you the list of insurers; if not, ask for it for each benefit you hold.
  • Search the firm on the FCA register. If it is an appointed representative, note the principal and search that too.
  • Ask: "Will I receive a written recommendation with your reasons at the start, and is each renewal advised?"
  • Ask whether anything is charged on top of insurer commission, including for a platform. What to ask about fees.

Where Alltoogether stands

We advise. Our terms of business set out that we advise on your insurance needs, base any recommendation on your stated demands and needs, and send a statement of demands and needs each year outlining our recommendations.

We are a whole-of-market employee benefits broker: we approach the insurers that write cover for a firm like yours, on the same specification, and bring the options back with our recommendation.

All Toogether Ltd (FCA 946194) is an appointed representative of Sante Partners Ltd (FCA 914023). Both are on the FCA register.

We built and run our own people platform, and it is included with broking at no extra charge. Employees see their cover, documents and how to claim in one place. The platform shows what it does; how it works sets out the service.

Questions people ask

What is the difference between an advised and a non-advised employee benefits broker?

An advised broker makes a personal recommendation about which policy suits your organisation, gives you its reasons, and must take reasonable care that the recommendation is suitable. A non-advised broker gives you information and arranges the cover you choose; the decision about suitability is yours. Both must be authorised by the FCA or be an appointed representative of a firm that is. The firm's terms of business say which service you are getting.

What does whole of market mean for an employee benefits broker?

It means the firm bases its recommendation on a fair and personal analysis of the insurers that write the cover you need, rather than a limited range it has chosen to work with. A firm must tell you which basis it uses before you buy, and a firm that does not recommend on that basis must give you the names of the insurers it deals with, also before you buy.

Is a benefits platform with a built-in broker the same as an advised broker?

Not necessarily. Some platforms arrange insurance on a non-advised basis from a limited list of insurers, which is a legitimate service but not the same as advice. Read the platform's terms of business for the words "advice" or "recommendation", and if it has not already given you its list of insurers for each benefit, ask for it.

Does non-advised mean the broker is not regulated?

No. A non-advised firm must be authorised by the FCA or be an appointed representative of a firm that is. Regulation and advice are separate questions: regulation says the firm may arrange insurance; the terms of business say whether it will recommend a policy to you.

What is an appointed representative?

A firm that carries out regulated activities under the responsibility of an FCA-authorised principal, rather than holding authorisation itself. It is a common arrangement. The FCA register lists each appointed representative with its principal, so you can check both.

Do employee benefits brokers charge for their employee platform?

Some do and some do not. Some firms include a platform with broking; others charge per employee per month, and some license a supplier's platform and put their own brand on it. Ask whether the platform is included or charged, whose software it is, and what happens to it if you change broker.

Is Alltoogether an advised, whole-of-market broker?

Yes. Alltoogether advises UK employers on insured employee benefits, including group private medical insurance, and approaches the insurers that write cover for each client on the same specification. Its own employee platform is included with broking at no extra charge. All Toogether Ltd (FCA 946194) is an appointed representative of Sante Partners Ltd (FCA 914023).

Sources and limitations

What this page is, and is not

This page is general information about the kinds of service an insurance intermediary can offer and how to check which one you are being offered. It is not a recommendation and not advice about whether any arrangement suits your organisation. It describes no other firm. Advising on whether a particular contract of insurance suits you is a regulated activity and is a separate conversation. Alltoogether is an appointed representative of Sante Partners Ltd, which is authorised and regulated by the Financial Conduct Authority.

Financial Conduct AuthorityThe Financial Services Register
Supports: that a firm's permissions, its status as an appointed representative and its principal can be checked independently, including ours
Published or updated: live register. Retrieved: 27 September 2026.
Limitation: the register records permissions and status. It does not show whether a firm advises on a given sale, which the firm's own terms of business state, and it says nothing about service quality.
Financial Conduct AuthorityFCA Handbook, ICOBS 4: Information about the firm, its services and remuneration
Supports: that an insurance intermediary must tell a customer, before the contract is concluded, whether it gives a personal recommendation and on what basis it selects insurers
Published or updated: current rules. Retrieved: 27 September 2026.
Limitation: the rules set what must be disclosed, not where. Most firms put it in their terms of business.
Financial Conduct AuthorityFCA Handbook, ICOBS 5: Identifying client needs and advising
Supports: that every sale starts from the customer's demands and needs, and that a firm which makes a personal recommendation must take reasonable care that it is suitable
Published or updated: current rules. Retrieved: 27 September 2026.
Limitation: the rules describe obligations. They do not grade any firm.

Related guides

ZF

Zak Fenton · Founder, Alltoogether

Written by Zak Fenton, MSc Workplace Health and Wellbeing (Distinction), founder of Alltoogether, a UK employee-benefits broker and workplace-health platform. Alltoogether is an appointed representative of Sante Partners Ltd, which is authorised and regulated by the Financial Conduct Authority (914023).

Last reviewed 27 September 2026.

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