As an insurance broker you win new clients through a sequence, not through a channel. Mediation is a licensed trade: anyone who wants to broker insurance contracts commercially in Germany needs a licence from the competent Chamber of Industry and Commerce under section 34d paragraph 1 of the Trade Regulation Act and has to be entered in the intermediaries register without delay under paragraph 10. You may advertise like anyone else; an advert or a website is not yet a business contact. The catalogue that makes up the initial information, meaning status, register number and type of remuneration, falls due at the first business contact with the individual prospect. So your process needs two things: a channel that has been checked legally, and a disclosure step that reliably fires the moment reach turns into contact. The channels themselves are unspectacular. In my observation referrals carry furthest in advice-heavy professions, a clearly defined target group usually beats a full-range offer, and with direct outreach you set the number of first contacts yourself, under the tightest legal limits.
I am not an insurance broker. I build websites and AI employees for small firms. Why this post stands apart from the others: for almost all of my clients the legal check ends with competition law, and here it only starts there. The general routes are in Finding New Clients as a Freelancer, and what office work can be handed off at all is in AI for Freelancers: What Pays Off. I am not a lawyer and this is not legal advice, it is a sorting of rules you can look up yourself. All provisions cited are German; quotations are my own translations, the binding wording is German.
The initial information and the moment it falls due
This is where professional law reaches into client acquisition. Section 15 paragraph 1 of the Insurance Mediation Regulation requires the details "at the first business contact", not at the point of signing and not already in general advertising. They include name and business address, the status together with the licence provision it rests on, whether you offer advice, the register number including the address of the register office "and how that entry can be verified", plus the address of the competent arbitration body.
A block of its own covers the money. You have to disclose "the type of remuneration received in connection with the mediation", whether it is "payable directly by the client or included in the insurance premium as commission or other remuneration", whether you receive other benefits, and whether the two are combined. That sits in the same list, it is not optional polish.
The form is set by section 16 of the same regulation: on paper, "in a clear, precise manner that is comprehensible to the policyholder", and free of charge. Another durable medium is allowed if the client could choose and picked it; delivery via a website only under further conditions. For the case that comes up most often in acquisition, paragraph 4 says: "In the case of telephone contact, the information is to be provided to the policyholder under paragraph 1 or paragraph 2 immediately after the first business contact."
What follows in practice is small: one finished initial information in text form that goes out with no rework, and a point in the process where it falls due automatically. Building that template so that it carries in paper and in text form is work; in a room with people who have already built one it goes faster.
What the advice has to document
The second block sits in the Insurance Contract Act, and it does not hang on the number of the conversation but on actual advice or mediation. Section 61 paragraph 1 obliges the intermediary to ask the client "about their wishes and needs", to advise them, to "state the reasons for any advice given on a particular insurance", and to document that. The qualifier in the same sentence matters: the duty applies "insofar as there is cause to do so given the difficulty of assessing the insurance offered or the person and situation of the policyholder", and the effort spent on advice should be proportionate to the premium. Section 61 paragraph 2 also allows a waiver, but only by way of a separate written declaration with a notice about the consequences for claims in damages under section 63.
For the broker, section 60 paragraph 1 comes on top: advice has to be based on "a sufficient number of insurance contracts offered on the market and of insurers". Where the selection is restricted, that has to be pointed out expressly before the client makes their contractual declaration, and under paragraph 2 the market and information basis has to be disclosed. The client can waive that under paragraph 3 only "by way of a separate written declaration".
When it has to arrive is set by section 62 paragraph 1: the information under section 60 paragraph 2 before the contractual declaration, the information under section 61 paragraph 1 before the contract is concluded, in each case "clearly and comprehensibly in text form".
Why that belongs in a post about client acquisition is answered by section 63: the intermediary is liable for damage caused by a breach of a duty under section 60 or section 61, unless the breach is not their fault. More new clients therefore means more documentation here, and the question is whether your process still carries it at double the volume.
Referrals: the channel that carries, with a limit of its own
In advice-heavy professions the referral is the most obvious channel, because trust is already there before the first appointment. Whether it is the strongest one for you only shows in your own count: record for a year where every new client came from. What makes it steerable is asking, and most people never ask. Three moments where it does not feel pushy: after a claim settled properly, after an annual review with a tangible result, and on an occasion the client raised themselves. The wording looks for a person: "Do you know anyone facing the same thing right now?" can be answered, "feel free to recommend me" cannot.
There is a limit here that other industries, the trades for instance, do not have. Section 48b paragraph 1 of the Insurance Supervision Act prohibits insurers and intermediaries from granting or promising "special remuneration" to policyholders, insured persons or beneficiaries. Under paragraph 2 that covers any direct or indirect benefit alongside the agreed performance, expressly including partial passing-on of commission, goods or services, and discounts, "unless it is of low value". Low value means rewards or gifts up to a total of 15 euros per insurance relationship and calendar year.
The bonus for a tip-off, elsewhere a normal referral scheme, runs into a very narrowly drawn exception here. The 15 euros are not a green light for a referral scheme but an upper limit inside a prohibition: anyone who really wants to give something away has the recipient, the occasion, the insurance relationship concerned and the specific benefit checked by an expert first. Asking costs nothing and is not affected.
A niche instead of a full-range offer
Choosing a target group means fixing who you work for, which of that group's risks you master, and which enquiries you pass on. Two rules of professional law argue for it. The first is the market breadth in section 60 paragraph 1: the sufficient number of contracts and insurers is easier to survey in a tightly defined field than across every line of business. The second is the training duty in section 34d paragraph 9 sentence 2 of the Trade Regulation Act: 15 hours per calendar year for the trader and for the employees involved. Fifteen hours in one field is real depth; spread across ten lines it is a box-ticking exercise. They do not establish professional suitability, which comes from product and market knowledge.
The niche is therefore not a marketing pose but the size at which you meet your own duties with reasonable effort. Which one fits your existing book is hard to decide alone at a desk; the question gets better once someone has already answered it for themselves.
Be findable for the need, not for the job title
Someone who knows they need a broker searches differently from someone who has a problem: the second group does not type a job title, it types its situation. That shapes your site: one thorough page per need question of your target group, with the process, the typical pitfalls and the documents required, instead of twenty thin location pages where only the place name changes. How that fits together with local visibility is in How Do I Get Found on Google? Local SEO, the order of the measures in SEO Basics for Small Businesses.
One peculiarity of this profession can serve as evidence. The intermediaries register under section 11a of the Trade Regulation Act is kept by the Chambers of Industry and Commerce and expressly serves the general public in verifying authorisation and scope of activity; information "is provided by way of automated retrieval over the internet or in writing". Putting your register number visibly on the website costs nothing and answers the first silent question an interested party has.
The limits of direct outreach
Direct outreach is subject to the same rules as everywhere, plus one of its own. The core limits in section 7 of the Act Against Unfair Competition: advertising by email needs the addressee's prior express consent, towards private individuals as much as towards businesses. For a phone call to another market participant at least presumed consent is enough, meaning an objective interest in exactly this call that is recognisable from the circumstances. For existing customers paragraph 3 holds an exception that requires four conditions at once. The wording and the details are in Automating Cold Outreach: Limits for AI, the data protection side of a contact list in Finding B2B Leads: LinkedIn and Alternatives.
The rule of its own is the initial information: it hangs on the first business contact, and on the phone it follows immediately after, under section 16 paragraph 4 of the Insurance Mediation Regulation. So anyone doing direct outreach needs, alongside permission for the channel, a ready-made way to send the mandatory disclosure: the template first, then the list.
What the groundwork looks like when an AI does it
Research before outreach is the part I handed off in my own business. I give Olaf, one of my AI employees, a town and a trade, and back comes a rated list with a reason, evidence and an A, B or C grade. Behind it sits a fixed tool chain: place research via the Google Places API, a technical quick check per website and screenshots of the page, plus mobile screenshots in the deep check. A lead only counts as one if the firm has an evidenced trigger and a contact address read from the imprint or the contact page. From my own runs in July 2026: 198 candidates checked across eight assignments, and in the seven town assignments with 20 candidates each typically 3 to 5 leads in that sense; the eighth was a differently built community list.
The decisive point for a regulated profession is in his rules, not in his output: he contacts nobody. No emails, no calls. Without a solid contact address there is no lead but a C grade, and addresses are never guessed. That keeps the moment at which the initial information falls due exactly where it belongs: he delivers the shortlist, you open the first business contact.
A publicly visible trigger does not turn a list into a free acquisition list, it is a research signal. Purpose, legal basis, data minimisation, accuracy, information duties and section 7 of the Act Against Unfair Competition all still have to be checked for storage, rating and contact, and an address in an imprint is not consent to advertising. On top of that comes the limit of the tool itself: the Google Maps Platform Terms of Service, version of 26 August 2026, prohibit under "No Scraping" copying and saving business names, addresses or reviews for use outside the services; what may be kept permanently under the service specific terms is essentially the place identifier, the place_id. So whatever stays in a list permanently belongs collected from the firm's own website: contact address, technical finding, screenshot. Research and outreach stay two separate gates: every record carries its source, its date, the permitted channel and a deletion deadline, and without a solid legal basis there is no contact.
My own runs were local service firms, searched by a technical trait of their website. For a broker working with commercial clients the logic is the same and only the search criterion differs. For private clients this route does not carry, because there is no public company page from which a trigger could be read.
Frequently asked questions
What do I have to tell a prospect at first contact?
The initial information under section 15 paragraph 1 of the Insurance Mediation Regulation, and specifically "at the first business contact", not already in general advertising. It covers name and business address, your status with the licence provision behind it, whether you offer advice, the type of your remuneration, your register number with a pointer to how the entry can be verified, and the address of the arbitration body.
In what form does the initial information have to be given?
Under section 16 of the Insurance Mediation Regulation on paper, clearly, precisely, comprehensibly and free of charge. Another durable medium is allowed if the client could choose; delivery via a website is tied to further conditions. After a first contact by telephone the information has to be provided immediately afterwards.
May I give something away for a referral?
Only within very narrow limits. Section 48b of the Insurance Supervision Act prohibits intermediaries from granting special remuneration to policyholders, insured persons and beneficiaries, expressly including passed-on commission, goods or services, and discounts. Gifts count as low value up to 15 euros per insurance relationship and calendar year, an upper limit and not a green light for a referral scheme. Asking for a referral is not affected.
Do I have to document every piece of advice?
The duty in section 61 paragraph 1 of the Insurance Contract Act is tied to cause and proportion: ask, advise, state the reasons for each piece of advice and document it, insofar as the difficulty of the insurance or the person and situation of the client give cause. Under section 62 paragraph 1 it has to reach the client in text form before the contract is concluded.
Can AI take over client acquisition for brokers?
The research and the pre-sorting yes, the conversation and the advice no. An AI can search publicly visible firms against fixed criteria, rate them and evidence the trigger. The moment a business contact exists, initial information, advice and documentation apply, and those hang on a licensed person.
What to do next
Start with the template, not with the list: the initial information that goes out in text form with no rework, and next to it the advice record that carries the reasons for your recommendation. Then decide on one target group and one need question, and write the first thorough page on it.
Only once that stands does the second route pay off, the one where you search instead of waiting. How the groundwork for it runs in my business and where it deliberately stops is on the page about Olaf, my lead scout. The template to rebuild on your own search criterion sits in my community Claude Practitioners, together with the people rebuilding it right now.
