The FMA has published nothing on soft commission spend since 2017. Here is what it found then
Source: FMA, Ensuring fair consumer outcomes from insurer benefits and campaigns (MR No. 2026-27)
The FMA's June 2026 insights on insurer benefits and campaigns contains no dollar figure. The last one it published was $34 million over two years, and 42% of those campaigns carried a sales target that would now be unlawful.
By Henry Smith · Regulation · 2026-06-11
The most recent dollar figure the FMA has published for soft commissions in New Zealand life and health insurance is $34 million, and it covers the two years to March 2017. Its June 2026 report on the same subject contains no figure at all (FMA, Insurer benefits and campaigns insights, June 2026, retrieved 20 August 2026).
We read the public documents. We were not briefed and we spoke to nobody.
What the FMA published on 11 June 2026
The FMA released the findings of its engagement with insurers on how they manage customers' interests during short-term sales campaigns and incentives. It had written to insurer chief executives in June 2025 after observing some insurers offering benefits and campaigns designed to drive business from intermediated channels such as financial advisers (FMA, MR No. 2026-27, retrieved 20 August 2026).
The report defines the two things it covers. Non-monetary benefits are advantages that may directly or indirectly incentivise employees, agents or intermediaries to encourage a purchase, with examples given as gifts, prizes, trips, tickets to sporting events, and professional development. Short-duration sales campaigns are limited-period initiatives with the same purpose, illustrated by a two-month campaign entering intermediaries into a prize draw for a trip with every new policy sold. The FMA notes both are sometimes called soft commissions.
Michael Hewes, the FMA's Director of Deposit-taking Insurance and Advice, is quoted saying that "these benefits and campaigns, or soft commissions, have a place but insurers should actively consider these risks to ensure their fair conduct programmes are designed to support fair treatment of consumers".
The findings are qualitative. Most insurers have processes to identify and manage the conflicts, but approaches vary. Some involve only a narrow group of stakeholders at the design stage. Some review at the end of a campaign, others monitor throughout. Some did not appear to have considered intermediary incentives at all when reviewing distribution methods. The FMA identifies four areas of focus: broader stakeholder involvement in design, clear governance and record-keeping, stronger monitoring of how incentives influence behaviour, and proactive outcomes-focused reviews rather than reliance on complaints.
No insurer is named. No campaign is named. No amount is given.
What the FMA did publish, in 2018
The same regulator, looking at the same practice, published a great deal of detail eight years ago. Its data covered April 2015 to March 2017 and came from nine insurers under a statutory notice: AIA, Asteron Life, AMP, Fidelity Life, nib nz, OnePath, Partners Life, Southern Cross and Sovereign, as the FMA listed them in October 2017 (FMA, Conflicted remuneration (soft commissions) in the life and health insurance industry, page 5, May 2018, retrieved 20 August 2026).
| What the FMA counted | Two years to March 2017 |
|---|---|
| Distinct soft commission offerings | 242 |
| Total spend | $34 million |
| Spend as a share of insurers' new-business revenue | 9% of $377 million |
| Spend on trips | $18 million across 29 trips |
| Advisers who received a trip | about 800 |
| Offerings requiring a sales target to qualify | 42% |
| Largest single insurer's spend | $12 million |
| Smallest single insurer's spend | $209,000 |
All figures from the FMA (executive summary and pages 9 to 13, retrieved 20 August 2026).
Individual campaigns were described. A competition in which advisers entered a draw to win a new BMW, with multiple entries based on the value of policies sold during the promotional period. A four-day trip to Queenstown for 12 advisers including heli-skiing, a wine tour and a motorsport driving experience, costing the insurer $103,000, or $8,600 an adviser. A trip to the Sunshine Coast for 29 advisers at $478,000. A trip to London for 20 advisers at $1.9 million, which is $95,000 an adviser. An earlier FMA review lists destinations offered as sales incentives including Shanghai, Prague, Las Vegas, Hollywood, Rome, New York and Rio de Janeiro, and records that one high-replacement adviser took ten such trips in four years (FMA, Replacing life insurance, who benefits?, page 5, June 2016, retrieved 20 August 2026).
Those are the only specifically documented New Zealand insurance sales campaigns we can source. We could not verify any campaign running in 2025 or 2026. They are not publicly documented, and the FMA's 2026 report does not document them either.
About 102 of those 242 campaigns would be unlawful today
Run the FMA's 2018 findings through the rules that took effect on 31 March 2025.
An incentive is a prohibited incentive if entitlement to it, or its nature or value, is determined by direct reference to a target or threshold relating to the volume or value of the services or products. The regulations give as a prohibited example a $1,000 bonus for selling at least 100 life policies in three months. A financial institution must not offer a prohibited incentive to an intermediary involved in providing its services or products (Financial Markets Conduct Regulations 2014, regulations 237E and 237G(2)(c), retrieved 20 August 2026).
The FMA found that 42% of the 242 soft commissions required the adviser to sell a particular number or value of the insurer's products. Applied to the count, that is about 102 offerings. Every trip in the review carried qualifying criteria, and the FMA states the criteria were typically set to reward the insurer's most successful advisers as measured by sales, often with a persistency condition allowing no more than 15% of the adviser's existing policies to lapse or be replaced during the qualification period.
On the plain wording of regulation 237E, roughly 102 of the 242 campaigns the FMA documented would be prohibited if an insurer ran them today. That reading is ours, not the FMA's, and it explains the shape of the 2026 report. The target-linked half of the practice is now unlawful. What the FMA is now supervising is the half that is not: the untargeted conference invitation, the professional development subsidy, the sponsorship, and the discretionary trip issued to advisers with whom the insurer "wanted to build a stronger relationship". The 2026 report's own line is that compliance with the incentives regulations alone is not enough.
The scale of the residual matters. Of the $34 million spent in 2015 to 2017, trips took $18 million across 29 offerings, an average of $620,690 each, while sponsorship took $1.7 million across 72 offerings, an average of $23,611 each. One trip was worth about 26 average sponsorships. Those averages are our division of the FMA's published totals by its published counts.
How to ask whether a campaign was running on your policy
The disclosure regulations reach non-monetary benefits explicitly. A commission or other incentive is defined as a commission, benefit or other incentive "whether monetary or non-monetary and whether direct or indirect" given as a consequence of the advice being given or the client acting on it (Financial Markets Conduct Regulations 2014, Schedule 21A clause 2(3), retrieved 20 August 2026). For each one, your adviser must tell you when it will be given, who gives it and to whom, and its amount or value or how that would be determined.
So the question to your financial advice provider is not "do you receive commission". It is whether any non-monetary benefit or short-duration campaign from the insurer applied to the placement of your policy, and what its value was.
The question to the insurer is different, because the insurer holds the record. The FMA states that CoFI requires insurers to keep records enabling adequate assessment of adherence to the fair conduct principle, including documented procedures for designing and approving benefits and campaigns. Ask the insurer whether a benefit or campaign was operating in the intermediated channel in the month your policy was issued.
If the answer to either matters to you, both the insurer and the adviser have an internal complaints process and an external dispute resolution scheme, and the FMA's 2026 report says relying on complaints alone is not sufficient monitoring. That cuts both ways: a complaint is still the mechanism that puts a specific case on the record.
The honest limits
There is no public register of insurer sales campaigns in New Zealand. We could not verify a single campaign running in the current period, and we are not going to describe one we cannot source.
The $34 million and everything under it describes April 2015 to March 2017 and nine specific insurers. The market, the regulatory regime and the corporate structures have all changed since. In January 2019 the FMA and the Reserve Bank reported that the last of the insurers offering overseas trips had announced they would stop, either immediately or within the following year (FMA and RBNZ, Life Insurer Conduct and Culture, page 18, retrieved 20 August 2026). Nothing here says any of those campaigns still exist.
Our reading that about 102 of the 242 offerings would now be prohibited applies a percentage the FMA reported to a count the FMA reported, then applies the current wording of regulation 237E to the qualifying criteria the FMA described. The FMA has not published that conclusion and may not agree with it. Whether a specific historical incentive would be caught depends on facts we do not have.
The 2026 report is guidance for insurers. It does not allege a breach by anyone, and neither do we.
QuoteHub is operated by Craig Smith Business Services Limited, trading as Smiths Insurance and KiwiSaver, a licensed Financial Advice Provider (FSP712931). Our arrangements with insurers are set out on our disclosure page.
Sources
- FMA, Ensuring fair consumer outcomes from insurer benefits and campaigns, MR No. 2026-27
- FMA, Insurer benefits and campaigns insights
- FMA, Conflicted remuneration (soft commissions) in the life and health insurance industry
- FMA, Replacing life insurance, who benefits?
- FMA and RBNZ, Life Insurer Conduct and Culture
- Financial Markets Conduct Regulations 2014
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