Good decisions rest on evidence. When a choice carries weight - when other people will live with the result - we make it on what can be shown and tested, rather than on instinct, on what we would prefer to be true, or on whoever argues with the most conviction. That discipline matters most when a profession sets the standard it will be judged against, because a standard is only as sound as the evidence beneath it.

We take this for granted almost everywhere else. In a courtroom, a case is won or lost on what can be proven; an advocate's confidence carries no weight until the evidence behind it survives testing. In medicine, a doctor examines and runs the tests before prescribing - the treatment follows the diagnosis, and the diagnosis follows the evidence.

Setting the standard for an entire profession deserves that same discipline. Since NIBA released the draft Insurance Brokers Code of Practice, much of the conversation has been about process. Who was consulted, and when. Whether a clause goes as far as the reviewer recommended. What a definition captures.

Those are fair questions, and the consultation exists to test them. Alongside them sits another one worth asking: what does the evidence say about how clients of insurance brokers actually fare?

It is a question the Board has kept returning to. Evidence of client outcomes, evidence of broker behaviour, and importantly, evidence of client impact - not hypothesis, not hyperbole, and not what might simply feel good to say.

Start with the footprint. NIBA's own research counts the premium brokers place with APRA-authorised insurers at $35.6 billion in 2024-25, or 46% of the market. General insurance reaches more Australians through a broker than it does without.

NIBA also asked advised clients about what they thought about the quality of service and professionalism that brokers provide across a range of areas, including risk advice and claims management and the evidence was compelling. As noted in Complexity to Clarity: The Broker Advantage, 95% view brokers as critical to claims resolution, and 98% report their claims have been successfully resolved. 91% say brokers helped them achieve better business outcomes, highlighting their role as trusted risk advisers.

Against that footprint, the complaints record needs reading properly. Broker clients accounted for 686 complaints to the Australian Financial Complaints Authority in 2025-26, out of roughly 117,000 the scheme received - under 0.6%.

Read next: From intermediary to indispensable

The profession's own monitoring committee gives a more textured picture, and it is worth being straight about it. Across fourteen years, the Insurance Brokers Code Compliance Committee's own-motion inquiries have most often found visibility, process and culture gaps rather than demonstrated client loss. But not always. Its review of strata practices this year found none of the representative agreements it examined met the Code's requirements, made nine breach determinations, and referred three brokers to ASIC and NSW Fair Trading. That is a real finding, and we treat it as one.

The Committee also reported that over calendar 2025, detrimental client financial impact across the whole Code-subscribing profession was $5.85 million, against the $44.6 billion of premium placed over that same calendar year - about $1.31 in every $10,000 in premiums. Small, but not nothing. Nor does the evidence let us claim too much. Breach and complaint data are self-reported, and the Committee is right to keep asking questions of firms reporting none.

Given these findings, strata remains the clearest pressure point, having been identified by AFCA, the IBCCC and in a number of state-based inquiries. Which is precisely why the draft Code extends remuneration disclosure to strata in full, across both residential and commercial strata corporations, whether or not the owners corporation is a retail client. Being evidence-led means going where the evidence points, including when it points at us.

The NIBA Board also committed to drafting the Code with clarity about what a Code is for. Standards operate in layers: the law sets the floor, licensing builds on it, NIBA membership requires compliance with the Code, and firms may then choose to go further again. A code that merely restates the law adds no protection - it becomes a cheat sheet for complying with something that already binds you. The point of a code is to be nimble where legislation cannot be, and to let a profession say: these behaviours matter, we are lifting our minimum above the legal one to protect clients from proven detriment, and we will be held to it. It will not stop everyone from doing the wrong thing, but it does set the standard the profession is prepared to be judged against.

Read next: Affordability and accessibility are regulatory outcomes too

Good decision-making rests on evidence. More than 300 individual pieces of feedback were recorded across written submissions, a member survey, a national webinar and a series of workshops and stakeholder sessions.

The response came from across the profession and beyond it. Sole practitioners and regional firms, mid-tier networks and the largest multinationals all made time to work through the draft. So did regulators and government agencies, the external dispute resolution scheme, consumer and financial counselling organisations, strata advocates, professional bodies and the Insurance Brokers Code Compliance Committee.

The Board finalises the Code in the coming weeks. The Code will be settled with that evidence in mind - fixing where the profession sees the floor, and where the opportunity lies to demonstrate professionalism well above it.

This is the third of a series of three op-eds that give insight into the thinking and the process behind the shaping of the new Code of Practice. You can read the previous two op-eds below.

Op-ed 1: The Profession’s Promise to Clients
Op-ed 2: Affordability and Accessibility are Regulatory Outcomes Too

Richard Klipin is Chief Executive Officer of the National Insurance Brokers Association (NIBA)