Sections 8 and 9 of the FAIS General Code do not change because the client bought on WhatsApp: the suitability steps, the record, and the copy the client gets.
A client messages on a Tuesday afternoon: "Just put me on the cheapest cover you can find, I trust you." Twenty minutes and eleven messages later there is a policy on risk. Eighteen months later the claim is short-paid because the sum insured was never discussed, and the FAIS Ombud asks the brokerage for its record of advice. The thread exists. The record does not — and those are not the same document.
The General Code of Conduct for Authorised Financial Services Providers and Representatives is channel-neutral. It was written for face-to-face and paper, it survived email, and it applies to a WhatsApp thread exactly as it applies to a boardroom. This is what sections 8 and 9 require, and how a brokerage that sells on WhatsApp actually satisfies them without pretending the conversation never happened.
Section 8 of the Code puts a sequence around advice. The provider must obtain appropriate and available information about the client's financial situation, financial product experience and objectives; conduct an analysis based on that information; and identify the financial product or products that will suit the client's risk profile and needs. An amendment added the obvious corollary: where nothing in your range fits, you decline to recommend rather than recommend the nearest thing.
On WhatsApp those three steps collapse into a handful of questions that take a client ninety seconds to answer. For a motor and household risk, the minimum honest set looks like this:
Those answers are the raw material for the analysis and, later, the evidence that one was done. Our motor quote on WhatsApp walkthrough sets the same sequence out as a message flow. The point is not the wording — it is that the questions were asked, the answers were recorded, and the recommendation refers back to them.
"Just give me a price" is the most common answer a broker gets, and the Code anticipates it. Where the client declines to provide information, or provides incomplete information, the provider must alert the client that there may be limitations on the appropriateness of the advice, and that the client should consider whether needs or circumstances that were not taken into account might be relevant.
On WhatsApp that warning has one enormous advantage over the same warning given on the phone: it is already in writing, timestamped, and delivered. Send it as its own message rather than burying it in a paragraph about premiums, and keep the wording plain — something along the lines of: you have asked me to quote without confirming the contents value, so this quote is based on the figure you gave me and may not be adequate if the actual value is higher. Then move on. The duty to advise is not a duty to nag, but it is a duty to say the thing clearly once and keep proof that you did.
Section 9 requires the provider to maintain a record of advice, and it lists what that record has to reflect: a brief summary of the information and material on which the advice was based; the financial products that were considered; and the product or products recommended, with an explanation of why the recommendation is likely to satisfy the client's identified needs and objectives. Where the recommendation replaces an existing product, the record must also carry the comparison described below. The Code also requires the provider to give the client a copy of the record of advice in writing.
A WhatsApp thread does part of that work and none of the rest:
| What the thread already proves | What it does not | What goes in the record |
|---|---|---|
| What the client told you, when, in their own words | That you analysed it | A short summary of the information the advice was based on |
| The quote you sent and the premium | Which other options you looked at and rejected | The products considered, named |
| That the client said yes | Why this product suits this client | The recommendation and the reasoning behind it |
| That a warning was delivered and read | That the client received the record itself | The client copy, sent in writing |
The gap in the middle column is where complaints are won and lost. A thread shows a transaction; a record of advice shows a decision. If your file has only the first, you are relying on a representative's memory of a conversation that happened three renewals ago — and, if that representative has since left, on nothing at all.
Moving a client from one insurer to another is the single highest-risk piece of advice a short-term broker gives, and the Code treats it that way. Where the recommended product replaces an existing one wholly or partially, the record of advice must include a comparison of the material differences between the terminated product and the replacement — costs and charges, any penalties, waiting periods, exclusions, benefits and guarantees — together with the reasons why the replacement is expected to be better for the client than retaining what they have. Where the advice is to replace a long-term insurance policy, the Code also requires notification to the issuers of both the existing and the replacement policy.
Ombud determinations in this area rarely turn on the price. They turn on a difference the client was never told about: a tracking device requirement the new insurer imposed and the old one did not, a waiting period that restarted, an excess structure that changed shape. If the comparison is not on the file, the brokerage is arguing from memory against a client with a decline letter in their hand.
A tool such as ORIS carries the operational half of that: a shared inbox where the whole thread sits against the customer record rather than on a representative's phone, AI-suggested drafts that a human approves before anything is sent, and a CSV export when the compliance file needs its own copy. It does not write your record of advice and it does not decide suitability — those are the adviser's, and no system should pretend otherwise. What it removes is the excuse that the conversation was on someone else's handset. Book a walkthrough if you want to see how the thread and the customer record stay together.
No. The thread is evidence of the interaction and part of your record-keeping, but section 9 asks for a record that reflects the information the advice was based on, the products considered, and the reasoning behind the recommendation. That is a document you write, even if every fact in it comes from the thread.
The requirement attaches to advice. Where no advice is given and the client is executing their own decision, the section 9 record is not triggered — but the disclosure and record-keeping duties still apply, and the burden of showing that no advice was given falls on the provider. In a WhatsApp conversation, that line is crossed more often than firms think.
The Code requires a copy in writing; it does not prescribe the medium. A message or an attached document sent to the number the client uses can satisfy that, provided it contains what section 9 requires and you keep proof of delivery. The safer pattern is a document attached to the thread rather than a wall of text.
Update it. The record should reflect the advice actually given and acted on, so a change in cover or sums insured means a new or amended record and a new copy to the client. Keep the earlier version as well, because the sequence of decisions is what a complaint will be judged against.
The FSP. Representatives act for the provider, and the provider carries the obligations under the Code, including having procedures and systems in place to produce these records on request. That is why access to the conversation history should never depend on one person's phone remaining in the business.
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