Loss adjuster or loss assessor: who acts for whom in UK claims

This page covers the United Kingdom, where claims handling is regulated by the Financial Conduct Authority and the loss adjusting profession is represented by the Chartered Institute of Loss Adjusters. It is written for readers on the insurer, broker and insured-defendant side. It describes the roles and the regulatory boundary between them. It is not advice about any individual claim and does not recommend appointing anyone.

Who instructs a loss adjuster, and who pays?

The Chartered Institute of Loss Adjusters describes a loss adjuster as “an impartial evaluator who specialises in the handling and resolution of insurance claims”. (cila.co.uk)

Most adjusters are instructed by insurers. On a commercial property or liability loss of any size, the insurer or the managing general agent appoints an adjusting firm to attend, establish cause and extent, check the loss against the policy wording, and recommend how the claim should be dealt with. CILA is direct about the fee: “If your insurance company has appointed a loss adjuster to handle your claim, your insurance company will pay that loss adjuster’s fee.”

The part most online explanations omit is that the instruction can run the other way. CILA also states: “If you have appointed a loss adjuster to work on your behalf, you will pay that loss adjuster’s fee.” A policyholder can engage an adjuster directly, and in that case the policyholder carries the cost. Adjuster and assessor are therefore not opposite ends of a fixed axis. They are two different professional roles, one of which can be instructed by either party.

The word that matters in CILA’s definition is impartial. An adjuster instructed by an insurer is not the insurer’s advocate. The adjuster’s function is to establish what happened and what the policy responds to, and the professional standard is applied whoever is paying. That is the opposite of how the role is usually characterised by firms selling the alternative.

What does a loss assessor actually do?

A loss assessor acts for the policyholder. The work is claim preparation and presentation: establishing and evidencing the extent of loss, quantifying the claim, assembling supporting documents, corresponding with the insurer and the insurer’s adjuster, and negotiating the settlement. Assessors typically charge the policyholder a fee, often calculated as a percentage of the settlement, and that fee is not normally recoverable under the policy unless the policy contains a specific claims preparation extension.

A loss assessor is not a court-appointed or statutory office. There is no reserved title and no single mandatory professional body. That is precisely why the regulatory question below matters more than any job title.

Why is only one of the two an FCA regulated activity?

Because the regulated activity is defined by whose interests you are serving.

The FCA’s Perimeter Guidance manual addresses this directly. PERG 5.7.1 states that “loss assessors acting on behalf of policyholders in the event of a claim are, therefore, likely in many cases to be carrying on this regulated activity” of assisting in the administration and performance of a contract of insurance. PERG 5.7.7 confirms that loss adjusting on behalf of a relevant insurer falls outside that activity, through the exclusion in the Regulated Activities Order for claims management on behalf of an insurer. (handbook.fca.org.uk)

The practical consequence is asymmetric and worth stating plainly. A firm acting for the policyholder is likely to need FCA authorisation for that activity. A firm doing broadly similar technical work on the insurer’s instruction relies on an exclusion and is captured instead through the insurer’s own regulatory obligations and its outsourcing controls. Anyone checking credentials should therefore search the Financial Services Register for an assessor, and look to CILA membership and chartered status for an adjuster, rather than assuming one register covers both.

When would you encounter each?

An adjuster usually appears at the point the insurer decides the loss needs independent technical assessment rather than desktop handling. The common triggers are value, complexity, a coverage question, a business interruption element, a subrogation prospect, a suspected fraud indicator, or a surge event such as a storm or flood where large numbers of claims need consistent handling. On smaller household claims many insurers handle in house or use a network of validators, so no adjuster is appointed at all.

Neither role should be confused with a third party administrator, which runs a whole portfolio of claims under delegated authority from an insurer and may instruct an adjuster as one of its suppliers on a particular file.

An assessor usually appears after the policyholder has become dissatisfied with progress, or after the policyholder has been approached by a firm offering to act. Both routes exist on domestic property losses in particular, which is why the sequencing question is worth asking early: did the policyholder seek this firm out, or did the firm find the policyholder.

For an insurer or a broker, the practical significance of an assessor on the other side of a claim is that quantum will be argued in more detail, documentation demands will increase, and correspondence will slow if the assessor’s fee depends on the final figure. None of that is improper. It is simply a different set of incentives in the room.

What does the insurer still owe regardless of who is appointed?

Appointing an adjuster does not move the regulatory duty off the insurer. ICOBS 8.1.1R requires an insurer to handle claims promptly and fairly, to provide reasonable guidance to help a policyholder make a claim and appropriate information on progress, not to unreasonably reject a claim, and to settle claims promptly once settlement terms are agreed. (handbook.fca.org.uk)

Section 13A of the Insurance Act 2015 adds an implied term into every contract of insurance that the insurer must pay any sums due within a reasonable time, and defines a reasonable time as including a reasonable time to investigate and assess the claim. The Act lists the type of insurance, the size and complexity of the claim, compliance with any relevant statutory or regulatory rules or guidance, and factors outside the insurer’s control as relevant circumstances. Where the insurer has reasonable grounds for disputing the claim it does not breach the term simply by not paying while the dispute continues, but “the conduct of the insurer in handling the claim may be a relevant factor”. (legislation.gov.uk)

Read together, those two provisions explain why adjusters are instructed at all. Investigation time is expressly contemplated, but the clock is not indefinite and the quality of the handling is itself assessable. An insurer that cannot evidence what it did, when, and on what information, is exposed on process even where the coverage position is sound. Complaints about regulated firms’ claims handling can be referred to the Financial Ombudsman Service. (financial-ombudsman.org.uk)

Do the two roles overlap?

In technique, substantially. Both examine cause, both quantify, both read the policy, both deal in schedules of loss and supporting evidence. Many individuals have worked on both sides during a career.

In duty, not at all. The adjuster’s product is an assessment of the claim against the policy. The assessor’s product is the policyholder’s claim, presented as strongly as the evidence allows. Where an assessor has been appointed, the adjuster is not assessing the loss for the assessor. Both are still working from the same underlying facts, and the quality of the evidence gathered at the time of the loss constrains both of them equally.

How do you tell which one you are dealing with?

Three questions settle it in most cases. Who appointed this firm. Who is paying its fee, and is that fee a percentage of the settlement. Is the firm on the Financial Services Register for assisting in the administration and performance of a contract of insurance, or is it presenting CILA membership and chartered status.

Titles alone will not tell you. “Claims consultant”, “claim preparer” and “claims manager” are all used, and CILA notes that policyholders may encounter professionals described as “claim preparers, claim managers, loss assessors, or similar”. The answer to who instructs and who pays is what defines the role, and it is also what defines the regulatory treatment.

Frequently asked questions

Sources

• Chartered Institute of Loss Adjusters, advice for policyholders: https://cila.co.uk/advice-for-policy-holders/
• Chartered Institute of Loss Adjusters, about us: https://cila.co.uk/about-us/
• FCA Handbook, PERG 5.7, assisting in the administration and performance of a contract of insurance: https://www.handbook.fca.org.uk/handbook/PERG/5/7.html
• FCA Handbook, ICOBS 8.1, claims handling: https://www.handbook.fca.org.uk/handbook/ICOBS/8/1.html
• Insurance Act 2015, section 13A: https://www.legislation.gov.uk/ukpga/2015/4/section/13A
• Financial Services Register: https://register.fca.org.uk/
• Financial Ombudsman Service: https://www.financial-ombudsman.org.uk/

Last reviewed: 16 September 2026

About Logincident. Logincident is a data and software company whose configurable platform captures structured evidence at source through a mobile app, forms, photographs, GPS and offline capture, and presents it in dashboards and reports. We are not a law firm or a claims handler, and nothing on this page is legal advice.