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FinTech Insurance: Liability & Risk Mitigation for Digital Financial Platforms

Updated 27 July 2026
By James Sampson
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Whether you operate an Electronic Money Institution (EMI), an Open Banking application (AISP/PISP), an AI-driven investment platform, or a Banking-as-a-Service (BaaS) architecture, your risk profile is uniquely different.

Building a Blended FinTech Insurance programme

A well structured FinTech insurance programme should evolve with the business. We work with a wide range of different insurers in the market that can meet your needs whether you're applying for FCA authorisation, raising your Series B, or looking to list your business on a public exchange.

The key is to build a programme that protects and supports your FinTech business for the next 12 months. Given there is always the option to adjust or move insurers as your risk profile and contractual requirements change.

FinTech Risk Matrix

FinTech Risk
Scenario
Primary Coverage
API Code Degradation
A bad deployment locks users out of a trading app during market volatility, causing missed trades.
Tech E&O / Professional Liability Module (Covers third-party financial loss claims).
FCA Regulatory Investigation
The FCA launches an enforcement investigation into the firm’s anti-money laundering (AML) controls following a system glitch.
Regulatory Defense Extension (Pays regulatory legal defense counsel fees and expenses).
Systemic Vendor Fraud
Hackers compromise an upstream payment gateway, diverting £500k of client funds.
Commercial Crime Insurance Triggers for fraudulent electronic and computer fraud).
Systemic Network Ransomware
A cyber criminal encrypts your database, threatening to leak client information and transaction histories.
Cyber Extortion & Data Privacy Modules (Activates 24/7 incident response, negotiation, and forensic containment).

Blended Technology & Financial Services

Traditionally insurers would treat technology and financial services as completely separate industries. However, there are now a growing number of insurers with products available that can afford blended cover to a failure of technology in a highly regulated financial service environment.

Failure of Technology Services

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Technology Professional Indemnity is a core protection for fintechs whose services are relied upon by clients, customers, and financial counterparties. If a system outage, API failure, coding error, or software defect causes a client to suffer financial loss, Tech PI is designed to provide a legal defence and compensatory damages. 

This is particularly important in fintech, where even a short interruption can affect payments, account access, transaction processing, reconciliations, or reporting. In 2026, the dependency placed on digital financial infrastructure means that software failures are no longer seen as minor technical issues, they are potential catastrophe events. Tech PI helps protect the business from the legal and financial consequences of those failures.

Contractual Liability

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Fintech businesses increasingly contract with Tier-1 banks, payment service providers, enterprise clients, and regulated institutions under highly negotiated Master Service Agreements. These contracts can include broad indemnities, service warranties, hold harmless provisions, and liability assumptions that may go beyond standard FinTech insurance.

We help align your Tech PI cover with the contractual reality of your business, reducing the gap between what you have agreed to in the MSA and what your insurer will actually cover. This is critical for fintechs seeking to engage with larger enterprise clients, where the weight of power in the contractual negotiations is one sided. Find out more about PI contractual risk management.

Cyber Resilience & Incident Response

Cyber Liability coverage will need to be blended with Technology Professional Indemnity for FinTech businesses because the proximate cause of a loss can be difficult to distinguish. 

A platform outage, data breach, unauthorised transaction, or processing error may involve both a cyber incident and a failure of the technology service being delivered to clients. If an insurer only provides one of these coverage sections, they could argue the cause of the loss isn’t covered.

Network Security & Privacy Liability

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Fintech firms can process some sensitive personal data, including identity, financial, and payment information. A privacy data breach or misuse of personal information can lead not only to client claims, but also to regulatory investigations and enforcement action.

Specialist cyber cover can help with legal defence costs, incident response expenses, customer notification, and certain regulatory exposures linked to UK GDPR and Financial Data Access obligations. For fintech businesses operating across borders, data sovereignty and privacy risk are now central to both compliance and insurability.

Critial Incident Response

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For firms serving financial institutions or operating within the European financial ecosystem, DORA has made rapid and structured incident response essential.

We arrange access to specialist forensic, legal, and breach response teams capable of supporting the mandatory 24-hour and 72-hour reporting windows, helping fintechs investigate incidents, contain damage, and meet their notification obligations.

Protecting The Board, Founders, & Investor's Interests

Traditionally insurers would treat technology and financial services as completely separate industries. However, there are now a growing number of insurers with products available that can afford blended cover to a failure of technology in a highly regulated financial environment.

Regulatory Defense (FCA)

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Directors and senior managers in fintech face an increasingly personal level of scrutiny. When regulators investigate governance failures, operational weaknesses, compliance breakdowns, or inadequate oversight of technology (including AI), individuals can be named directly.

Directors and Officers (D&O) insurance helps protect directors by covering legal costs associated with investigations, interviews, Section 166 reviews, and claims alleging failure to supervise, failure of oversight, or breach of duty. 

Investor Requirement

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Fintech investors may request D&O insurance because they would like the comfort that they could later bring a claim for mismanagement or a shareholder action. 

In fintech, leadership teams make decisions in areas that attract a high level of scrutiny. If something goes wrong, investors know that founders, board members, and senior managers may face claims from regulators, shareholders, creditors, customers, or other stakeholders.

D&O insurance can help protect those individuals by covering defence costs, settlements, and damages awarded by a court.

Criminal Taking & Social Engineering Fraud

Many people assume that the Cyber section will protect against the theft of money, securities, or client funds, however the Crime section will need to be purchased in addition.

Crime Insurance can provide specific protection for employee dishonesty, funds transfer fraud, social engineering, forgery, mandate fraud, and third-party fraud.

APP Fraud & Payments Theft

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The rise in fraudulent payment instruction scams has made commercial crime cover a vital component of fintech resilience. In a sector built around trust, speed, and digital movement of funds, a single social engineering event can result in immediate financial loss, regulatory scrutiny, and severe reputational damage.

Commercial Crime insurance can help protect against losses arising from APP fraud, impersonation scams, and payment diversion events, where staff or systems are manipulated into sending funds to the wrong destination.

Employee Fidelity

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Not all threats come from outside the business. Employee dishonesty, internal fraud, and embezzlement remain important exposures, particularly for firms handling client money, financial data, access credentials, or payment instructions.

Employee Fidelity cover protects the business against losses caused by internal bad actors, including theft of money, securities, or other assets. In some parts of the fintech market, this is also an expected or mandatory feature of the insurance programme when seeking authorisation, partnership approval, or institutional credibility.

Expert Open Market Advice & Advocacy

We bring access to specialist London market insurers and the ability to negotiate coverage, which is critical for fintechs dealing with banks, PSPs, FCA scrutiny, and demanding procurement frameworks.

Beyond placement, we support clients with claims advocacy, policy alignment, and strategic advice, helping ensure their insurance program is suitable for scaling, contractual requirements, changes in regulation, and overall resilience.

Claim Advocacy

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A system outage, APP fraud event, data breach, or compliance failure can damage client trust, trigger reporting obligations, and put investor confidence at risk. Unfortunately, FinTech claims can be complex and involve multiple policy triggers, such as technology failure, regulatory investigation, client financial loss, fraud, cyber event, and contractual disputes all at once.  

Without expert claim advocacy, there is a real risk that insurers view the issue too narrowly, dispute which policy should respond, or delay decisions whilst your business is under pressure.

Fair Value Statement

We assess insurers based on financial strength, wording quality, claims performance, and their ability to support FCA and non-regulated businesses. For fintech businesses, fair value means the insurance solutions we offer provide fair value in line with the FCA Consumer Duty.

Your Obligations

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Under the Insurance Act you are required to make a Fair Presentation of Risk which means you have a  duty to disclose every material circumstance which you know or ought to know, or failing that, disclose sufficient information that would put a prudent insurer on notice to ask further questions. 

If you fail to make a fair presentation of risk, the Act provides insurers with a range of proportionate remedies based on the nature of the failure. If the failure was deliberate or reckless, the insurer may void the contract, refuse all claims, and retain the premiums paid.

Frequently Asked
Questions

Will our Cyber or PI payout for APP Fraud?

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Authorised Push Payment (APP) fraud is rarely covered by PI or Cyber. To protect your balance sheet against mandatory reimbursement rules, you require a specialised Commercial Crime policy with an Electronic Transfer Fraud extension. At Indemnity we are specialists at bridging this gap.

Do we have cover for 'Downstream' data breaches?

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Under the Financial Data Access (FiDA) framework, your liability increases the moment you share data via APIs. The policies we can arrange provide Third-Party Data Liability, protecting you if a vulnerability in your API leads (Open Banking) to a breach of your client’s customer data at a "Downstream" partner.

A Bank is demanding a £10m PI & Cyber limit. How do we secure this?

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We use a "Primary and Excess" (Layered) structure. By placing your first £2m - £5m with a specialist fintech lead and adding "Excess of Loss" layers from the London Market, we can provide the high-capacity limits required to pass banking procurement without over-inflating your premium.

Meet the Brokers

Simon Taylor (ACII)
Chartered Insurance Broker
A Chartered Insurance Broker with over 25 years experience in the Technology PI, Cyber, and D&O space. Having held senior positions at Willis, QBE and Chubb, he is well placed to advise his clients on obtaining comprehensive and cost-effective protection.
James Sampson
Account Executive
Bringing analytical experience together with a client-focused mindset. He has built a wealth of experience advising businesses on their insurance requirements, delivering tailored solutions and providing risk management expertise across a wide range of industries.
Ryan Nevin
Account Broker
Combining client-focused experience with a keen analytical mindset and attention to detail combined with problem solving skills. He has since continued to build experience, developing a strong understanding of the risks faced by businesses across a range of sectors.