Lead generation for insurance brokers in Australia

Lead generation for insurance brokers in Australia has to start from consent: ASIC’s hawking guidance (RG 38) treats a call, meeting or AI chat with a retail client as unsolicited unless they agreed to it first, and consent can be relied on for six weeks (up to 12 where a medical examination is needed). Choose a provider on consent handling first, price second.

At a glance: choosing lead generation as an Australian insurance broker

• The rule that shapes everything: under s992A of the Corporations Act you must not offer a financial product to a retail client during or because of unsolicited real-time contact. ASIC says this covers calls, face-to-face, instant messages and AI chat-bots.
• Who carries the risk: ASIC’s view is that the person commissioning a chat-bot, or under whose licence it runs, is responsible for any offer it makes. Outsourcing does not move the liability off your AFSL.
• Your cheapest pipeline: clients already on your book. A renewal of a substantially similar policy held in the last 30 days is permitted; a new product cross-sold on the same unsolicited call is not.
• What a setter may do: answer enquiries, confirm the client’s request for contact, and book a review with a licensed person. No quotes, no offers, no advice.
• How LeadsNow is paid: a share of the revenue we help generate (5-20%) or a per-appointment fee, not a retainer.

How do insurance brokers get new clients in Australia without hawking?

Insurance brokers get new clients without hawking by making the client the one who asks for the conversation. ASIC’s Regulatory Guide 38, written for the regime that started on 5 October 2021, says unsolicited contact means real-time contact the consumer did not consent to, and that consent must be positive, voluntary, clear, and given before the contact starts.

Three details in RG 38 decide how a broker’s lead generation has to work:

1. Non-real-time invitations are allowed. RG 38.35 says an offeror may use communications that are not in real time, such as a letter or email, to encourage a consumer to request future contact. The later call must still comply. RG 38.38 adds that whether a text message is real-time depends on the circumstances, so keep SMS invitations one-way.
2. AI does not get a pass. RG 38.36 extends the prohibition to instant messages and chat-bots, and RG 38.37 says hiring a third party does not get around it.
3. Consent expires. RG 38.111 says an offeror may rely on a consumer’s consent only for the six weeks after it is given, or up to 12 weeks where a medical examination is needed before the product is issued, and RG 38.114 says those limits apply to insurance brokers too. A quote request from March is not permission to call in September.

The hawking prohibition applies to retail clients only. In general insurance that includes individuals and, for many products, small businesses; the definition is in s761G of the Corporations Act. Check each client class with your compliance manager. This page is general information, not legal advice.

The broker consent ladder: what a setter may do at each rung

The broker consent ladder maps each way an insurance lead reaches you to what an appointment setter, human or AI, may do before a licensed person takes over. It is built from the RG 38 paragraphs cited above and the ACMA’s rules for calls and messages. It is a working guide for a compliance conversation, not a substitute for one.

The broker consent ladder’s one-line rule: the setter’s job is to turn interest into a recorded, scoped request for contact and a booked time, and to stop there.

Where an insurance broker’s leads leak

An insurance broker’s leads leak at three points, and none of them is a shortage of enquiries.

• The consent gap. An enquiry arrives by web form, the broker is in a client meeting, and by the time anyone calls, the form’s consent wording turns out not to cover a call. The lead gets an email that is never answered.
• The renewal calendar. Personal and small-business general insurance typically renews annually, so a prospect is realistically winnable in the weeks before one date a year. A broker who does not record a prospect’s renewal date loses them for 12 months, not for a week.
• The single-line client. A client who holds only motor or only home cover with you is the cheapest cross-sell you have, and RG 38 means you cannot just ring them about a new product. The fix is an invitation that asks them to request a review, run on the book at scale.

Our page on database reactivation in Australia covers the mechanics of working a dormant client list. For a broker, the RG 38 overlay means the first touch is always non-real-time.

Comparing the ways insurance brokers buy growth

Each channel below is compared on how you pay, where the hawking and spam exposure sits, and who owns the client relationship afterwards. No reliable public benchmark exists for insurance broker cost per appointment in Australia, so the table compares structure, not prices.

The Do Not Call Register only covers home, personal mobile and fax numbers. The ACMA says business numbers cannot be registered, which is why cold calling a commercial prospect’s office line carries different risks from cold calling a household.

What running compliant lead follow-up in-house costs a brokerage

Running this yourself is entirely possible, and a disciplined brokerage should try it before paying anyone. Here is the arithmetic for a renewal-review programme on a book of 1,800 retail clients, with illustrative inputs.

• Renewals a month: 1,800 ÷ 12 = 150.
• Invitations: one email and one SMS per renewal, about 45 days out, plus a reminder: 450 messages a month, mostly automatable.
• Replies to work: if 20% reply asking for a review, 30 conversations a month, each needing about 15 minutes to confirm the request, record consent and book: 7.5 hours.
• Inbound enquiries: 60 a month at six contact attempts of 3 minutes each: 18 hours.
• Total: roughly 25 to 30 hours a month of setter time, plus consent record-keeping and a monthly compliance check of scripts.

The hours are manageable. What usually breaks is consistency: renewal invitations slip in busy months, consent records live in three systems, and calls get made on expired consent. If you run it in-house, give one named person the renewal calendar and the consent log, and review both monthly.

How a pay-per-result setter programme runs for an insurance brokerage

For an insurance brokerage, a done-for-you setter programme should stay on the setter rungs of the broker consent ladder: answer inbound enquiries within minutes where the client asked for a call, send non-real-time invitations to your own book with Spam Act consent, confirm and record each client’s request for contact, and book reviews into your authorised representatives’ calendars. Every script should be approved by your compliance lead before it runs, because under RG 38.37 the responsibility for what an AI setter says sits with your licence.

You pay on results: a revenue share of 5-20% of the sales we help generate, or roughly 1-5% of closed-deal value per appointment, rather than a retainer. Our headline record is 50,769+ AI-booked sales appointments since 2017 and 1M+ leads generated. The closest of our filmed case studies to insurance broking is 121 Brokers, a finance brokerage run by Sam Tajvidi. The wider set of broker and adviser services sits on our finance and broking hub, and financial planning practices, whose regulatory position differs, are covered on lead generation for financial advisers.

This model is wrong for a brokerage whose growth is entirely commercial wholesale placements won through relationships at the underwriter level. There, a setter adds little.

Frequently asked questions

Can insurance brokers cold call in Australia?

Not to offer products to retail clients. ASIC’s RG 38 explains that s992A prohibits offering a financial product to a retail client during or because of unsolicited real-time contact, including calls, meetings, instant messages and chat-bots. Wholesale clients are outside the prohibition, but other laws still apply. Confirm with your compliance manager.

Can an AI chat-bot or AI setter contact insurance leads?

Only within the consent the client gave. RG 38 says the hawking prohibition is technology neutral and covers chat-bots, and that the person commissioning the chat-bot, or under whose licence it runs, is responsible for any offer it makes. An AI setter should confirm the request and book the appointment, not quote or offer.

Can I call an existing client about their renewal?

Generally yes for a like-for-like renewal. RG 38.28 says an existing client can be contacted about a substantially similar product they held within the previous 30 days. Offering a different product on that call is a separate question and needs the client’s consent to be contacted about it.

Do insurance brokers need to give a general advice warning when booking appointments?

Not if the booking conversation contains no advice. ASIC’s guidance on giving financial product advice says a general advice warning is required when general advice is given. A booking script should be designed to contain no advice at all, so that any advice, and its warning, comes from the licensed broker in the review itself.

How long does consent to be contacted last under the hawking rules?

Under RG 38, a broker can rely on a client’s consent for six weeks after it is given, or up to 12 weeks where a medical examination is needed before cover is issued, and consent can be withdrawn at any time. After that, a broker should send a non-real-time invitation and wait for the client to ask for a call again.