Financial ombudsman from 2027 and test purchases: how client protection is changing and what it means for intermediaries

Protecting consumers of insurance services is no longer a matter for insurers alone: the new control tools affect intermediaries as well, one way or another. Below are three changes that are already in effect or will take effect in the coming months.

1. A single Financial Ombudsman Service

On 30 September 2026, the council of the service elected the chief financial ombudsman and the sector ombudsmen. Maria Khadzhieva became chief financial ombudsman and, at the same time, ombudsman for the securities market, and Kanat Aligulov became ombudsman for the insurance sector. The election was held under the Law of 16 January 2026 on amendments concerning the regulation and development of the financial market, communications and bankruptcy. The service will start operating on 1 January 2027. It will bring together the existing banking, microfinance and insurance ombudsmen. Its tasks include identifying systemic problems and recurring practices of supervised organisations based on an analysis of complaints. Complaints are reviewed free of charge for clients.

Under the draft Law "On the Insurance Market" (Article 172), a decision of the financial ombudsman is binding on the insurance organisation if the complainant has agreed to it in writing. If the insurer fails to comply with the decision, the ARDFM applies supervisory response measures to it. Parties who disagree with the decision may go to court. These provisions are still only a draft.

2. Mystery shopping and a ban on mis-selling

ARDFM Resolution No. 3 of 27 January 2026 requires insurers to have an independent unit for the protection of clients' rights. This unit checks how employees and agents comply with the requirements by conducting mystery shopping of contracts, checks the transparency of terms and identifies sales of unsuitable products. It also monitors compliance with the decisions of the insurance ombudsman. The insurer's board of directors approves rules of conduct for employees and agents that expressly prohibit misleading clients, concealing material information and imposing products. The same resolution added an excessive complaints ratio to the list of factors indicating a deterioration in the insurer's financial position.

3. Regulation of assistance in obtaining payouts

The draft law singles out assisting a client in obtaining a payout as a separate activity (Article 159). This will be done by an insurance consultant. To work, a consultant must be entered in a register maintained by an association of insurers and brokers, and later by an SRO. An individual must have a higher education. A consultant may not receive a payout on behalf of a client, accept remuneration from the insurer or buy out the right to claim a payout, and any such transaction is deemed void. The insurer will leave without consideration claims from persons who are not on the register, unless they are relatives, lawyers, brokers or fall under other exceptions listed in the draft. For intermediaries involved in guaranteed payouts from the IPGF, the draft sets a cap on remuneration: 10% of the payout for general insurance and 1% for life insurance (Article 208).

What this means for agents and brokers

• Every client complaint now affects the insurer's supervisory indicators. Insurers will therefore more often remove agents with many complaints from their register.
• Keep evidence that the client has been made aware of the rules and terms of the contract: in a dispute before the ombudsman, this is the main argument.
• Under the draft, the status of an agent cannot be combined with that of a payout consultant. Those who help clients obtain payouts for a fee should decide in advance which role to choose.
• Brokers should note that the Financial Ombudsman Service will also consider disputes over brokerage services. Judging by the ARDFM announcement, this refers to brokerage services on the financial market. How this will affect insurance brokers will be clarified by the service's documents.