Commission Disclosure

Penny Life Limited trading as This is Penny acts as an intermediary (broker) between you, our client, and the life insurance company (“provider”) with whom we place your business. Our role is to help you to select the pension product that best meets your needs.

The Background

Pursuant to provision 4.58A of the Central Bank of Ireland’s September 2019 Addendum to the Consumer Protection Code, all intermediaries, must make available in their public offices, or on their website if they have one, a summary of the details of all arrangements for any fee, commission, other reward or remuneration provided to the intermediary which it has agreed with its product producers.

Standard Commission Terms

The Intermediary (Broker) acts between you, the consumer, and the product provider with whom they place business.

What is Remuneration
(ruh·myoo·nuh·ray·shn)

Remuneration is the payment earned by the intermediary for work undertaken on behalf of both the provider and the consumer. The amount of remuneration is generally directly related to the value of the products sold.

We, Penny Life t/a This is Penny acts as intermediary (Broker) between you, the consumer, and the product provider with whom we place your business.

What is Commission?

For the purpose of this document, commission is the payment earned by the intermediary for work undertaken on behalf of both the provider and the consumer. The amount of commission is generally directly related to the premium or value of the products sold. There are different types of commission models:

Single commission model : where payment is made to the intermediary shortly after the sale is completed and is based on a percentage of the premium paid/amount invested/amount borrowed.

Trail/Renewal commission model: Further payments at intervals are paid throughout the life span of the product.

Indemnity Commission

Indemnity commission is the term used to describe a commission payment made before the commission is deemed to be ‘earned’. Indemnity commission may be subject to a clawback (see below) if the consumer lapses or cancels the product before the commission is deemed to be earned. Other forms of indemnity commission are advances of commission for future sales granted to intermediaries in order to assist with set up costs or business development.

Life Assurance/Investments/Pension Products

For Life Assurance products commission is divided into initial commission and renewal commission (related to premium), fund based or trail relating to accumulated fund.

Trail commission, bullet commission, fund based or renewal commission are all terms used for ongoing payments. Where an investment fund is being built up though an insurance-based investment product or a pension product, the increments may be based on a percentage of the value of the fund or the annual premium. For a single premium/lump sum product, the increment is generally based on the value of the fund.

Examples of products include Life Protection, Regular Premium Life Assurance Investments, Single Premium (lump sum) Insurance-based Investments, and Single Premium Pensions.

Clawback

Clawback is an obligation on the intermediary to repay unearned commission. Commission can be paid directly after a contract is concluded but is not deemed to be ‘earned’ until after a specified period of time.

If the consumer cancels or withdraws from the financial product within the specified time, the intermediary must return commission to the product producer.

Fees

The firm may also be remunerated by fee by the product producer such as policy fee, admin fee, or in the case of investment firms, advisory fees.

Other Fees, Administrative Costs/ Non-Monetary Benefits A non-monetary benefit could include (but is not limited to):

  • Attendance at product provider seminars Industry Educational Seminars

  • Use of Product Providers resources

  • Co-branded literature

  • Product Provider hospitality

  • Assistance with Advertising/Branding

Aviva Life & Pensions Ireland DAC

Aviva Life Savings, Investments, PRSA &
Annuities

Aviva Life Savings, Investments, PRSA &
Annuities

Single Contribution PRSA

Single Contribution PRSA

Default

Default

Max

Max

Annuities

Annuities

Max

Max

Default

Default

Regular Contribution PRSA

Regular Contribution PRSA

Default

Default

Max

Max

Initial Commission 

Initial Commission 

Initial Commission

n/a

n/a

7.5% 

7.5% 

2%

2%

3%

3%

n/a

n/a

17.5%

17.5%


Trail


Trail

n/a

n/a

0.25% 

0.25% 

n/a

n/a

n/a

n/a

n/a

n/a

0.25%

0.25%


Bullet


Bullet

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Aviva Life
Individual Pensions

Aviva Life
Individual Pensions

Default

Default

Max

Max

Initial Commission 

Initial Commission 

n/a

n/a

Regular Premium: 20%
Single Premium: 5%

Regular Premium: 20%
Single Premium: 5%


Trail


Trail

n/a

n/a

1% each year thereafter

1% each year thereafter


Bullet


Bullet

n/a

n/a

Single Premium: n/a Regular Premium: 40%

Single Premium: n/a Regular Premium: 40%

Aviva Life
ARF / AMRF

Aviva Life
ARF / AMRF

Default

Default

Max

Max

Aviva Life
ARF / AMRF

Aviva Life
ARF / AMRF

Default

Default

Max

Max

Initial Commission 

Initial Commission 

n/a

n/a

5%

5%

Initial Commission 

Initial Commission 

n/a

n/a

Regular Premium: 10%
Single Premium: 2%

Regular Premium: 10%
Single Premium: 2%


Trail


Trail

n/a

n/a

1% each year thereafter

1% each year thereafter


Trail


Trail

n/a

n/a

n/a

n/a

New Ireland Assurance Company PLC

New Ireland Assurance Company plc is regulated by the Central Bank of Ireland. A member of Bank of Ireland Group.

New Ireland
Single Contribution Products

New Ireland
Single Contribution Products

New Ireland
Single Contribution Products

Single Contribution Pension

Single Contribution Pension

Single Contribution Pension

Max

Max

Single Contribution PRSA

Single Contribution PRSA

Single Contribution PRSA

Max

Max

Approve (Min) Retirement Funds

Approve (Min) Retirement Funds

Approve (Min) Retirement Funds

Max

Max

Annuities

Annuities

Annuities

Max

Max

Single Premium
Investment Policies

Single Premium
Investment Policies

Single Premium
Investment Policies

Max

Max

Initial Commission

Initial Commission

5%

5%

7%

7%

5%

5%

3%

3%

4%

4%

Clawback
Period

Clawback
Period

Clawback
Period

5 years

5 years

5 years

5 years

n/a

n/a

n/a

n/a

3%

3%

Trail
Commission (p.a.)

Trail
Commission (p.a.)

Trail
Commission (p.a.)

1% p.a.

1% p.a.

0.5%

0.5%

1% p.a.

1% p.a.

n/a

n/a

1% p.a.

1% p.a.

Information correct as at 31 March 2020 and may be subject to change

New Ireland
Single Contribution Products

New Ireland
Single Contribution Products

New Ireland
Single Contribution Products

Regular Contribution Pension

Regular Contribution Pension

Regular Contribution Pension

Max

Max

Regular Contribution PRSA

Regular Contribution PRSA

Regular Contribution PRSA

Max

Max

Regular Premium
Investment Policies

Regular Premium
Investment Policies

Regular Premium
Investment Policies

Max

Max

Annuities

Annuities

Annuities

Max

Max

Initial Commission

Initial Commission

25%

25%

7%

7%

5%

5%

10%

10%

Clawback
Period

Clawback
Period

Clawback
Period

5 years

5 years

5 years

5 years

n/a

n/a

5 years

5 years

Renewal / Flat
Commission

Renewal / Flat
Commission

Renewal / Flat
Commission

8% p.a.

8% p.a.

6%

6%

1% p.a.

1% p.a.

2.5%

2.5%

Trail
Commission (p.a.)

Trail
Commission (p.a.)

Trail
Commission (p.a.)

1% p.a.

1% p.a.

0.5%

0.5%

1% p.a.

1% p.a.

0.5%

0.5%

Zurich Life Assurance PLC

Single contribution products (Pensions, Investments)

Single contribution products
(Pensions, Investments)

Single contribution products
(Pensions, Investments)

Single Contribution Pension

Single Contribution Pension

Max

Max

Single Contribution PRSA (Standard)

Single Contribution PRSA (Standard)

Max

Max

Single Contribution PRSA (Non-Standard)

Single Contribution PRSA (Non-Standard)

Max

Max

Approved (Minimum) Retirement Funds

Approved (Minimum) Retirement Funds

Max

Max

Annuities

Annuities

Max

Max

Investment Bonds

Investment Bonds

Max

Max

Trustee Investment Plans

Trustee Investment Plans

Max

Max

Up front commission 

Up front commission 

5.50%

5.50%

5.50%

5.50%

5.0%

5.0%

5.0%

5.0%

3.0%

3.0%

5.0%

5.0%

5.0%

5.0%

Trail commission

Trail commission

0.50%

0.50%

0.00%

0.00%

0.50%

0.50%

0.50%

0.50%

n/a

n/a

0.50%

0.50%

0.50%

0.50%

Commission clawback:

Commission clawback typically does not apply on single contribution products Regular contribution products (Pensions, Savings)

Regular contribution products 

Regular contribution products 

Regular Contribution Pension

Regular Contribution Pension

Max

Max

Regular Contribution PRSA (Standard)

Regular Contribution PRSA (Standard)

Max

Max

Regular Contribution PRSA (Non-Standard)

Regular Contribution PRSA (Non-Standard)

Max

Max

Initial
commission

Initial
commission

20%

20%

5.0%

5.0%

5.0%

5.0%

Renewal / Bullet
Commission

Renewal / Bullet
Commission

3.0% renewal

3.0% renewal

5.0% renewal

5.0% renewal

5.0% renewal

5.0% renewal

Trail commission

Trail commission

0.50%

0.50%

0.0%

0.0%

0.50%

0.50%

Penny Life trading as This is Penny is regulated by the Central Bank of Ireland

© 2025, Penny Life. All Rights Reserved.

Penny Life trading as This is Penny is regulated by the Central Bank of Ireland

© 2025, Penny Life. All Rights Reserved.

Penny Life trading as This is Penny is regulated by the Central Bank of Ireland

© 2025, Penny Life. All Rights Reserved.