July 27, 2023

UK Insurance Horizon Scanner - July, August and September 2023

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Hogan Lovells

A snapshot of key market and regulatory developments expected to impact the UK insurance sector over the next few months.

JULY	7	Definition of “insurance holding company”: Following PRA Policy Statement PS6/22 of July 2022 setting out its approach to interpreting and applying the definition of “insurance holding company “ for purposes of Group Supervision Part of the PRA rulebook, the Glossary Part amendments and the expectations set out in the updated version of SS9/15 will come into effect on 7 July 2023.
	31	Consumer Duty: New consumer duty implementation period ends, and new rules apply for new and existing products or services that are open to sale or renewal.
	31	Customers in financial difficulties: Date FCA's proposed insurance guidance on supporting customers in financial difficulty expected to come into force (immediately after commencement of the Consumer Duty Instrument 2022 (FCA 2022/31)), at which time it will supersede the insurance parts of the COVID-19 guidance.
	31	Solvency II (UK): deadline for responses to PRA’s proposals in Chapter 11 of CP 12/23 (minor amendments to rules arising as a consequence of HM Treasury’s reforms to the risk margin).
AUGUST	29	Financial Services and Markets Act 2023: Section 58 and Schedules 12 and 13 – Insurers in financial difficulties - come into force. FSMA 2023 (Commencement No.1) Regulations 2023: revocation of subordinated legislation that is retained EU law relating to financial services and markets as listed in the Schedule to the Regulations
	31	Money and Pensions Service (MaPS): deadline by which all FCA – regulated pension providers must comply with the new section 19.11 of COBS which sets out the requirements for operators of relevant pension schemes to connect with the pensions dashboard system and provide pension benefit details on request. Certain providers have an extension until 31 October 2023.
SEPTEMBER		ESG: Publication of final TNFD recommendations
		Solvency II (UK): second PRA consultation paper expected.
	1	Solvency II (UK): deadline for responses to PRA’s proposals set out in Chapters 2 to 10 of CP 12/23. PRA then expects to publish final policy around the end of the year.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.