UK Insurance Horizon Scanner - March, April and May 2024

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Coming up in March, April and May.

MONTH

DATE

DETAILS

MARCH

5

Non-financial misconduct: Lloyd’s Managing Agents & London Market Insurers, and Lloyd’s and London Market Insurance Intermediaries, to complete a survey about incidents of non-financial misconduct (NFM) at their firm in response to FCA letter and survey.

15

Operational Resilience: Closing date for responses to FCA/PRA consultation on Operational Resilience: Critical Third Parties to the UK Financial Sector consultation paper.

APRIL

5

Insurance Distribution: New FCA rules replacing the IDD delegated regulations come into force.

26

Solvent exit plans: Closing date for responses to PRA consultation on solvent exit planning for insurers (CP2/24). The PRA expects to publish feedback and final policy in H2 2024 with implementation in Q4 2025.

30

AI: FCA, PRA and BoE to publish an outline of their strategic approach to AI regulation in the financial services sector.

MAY

31

ESG: all authorised firms need to comply with the FCA anti-greenwashing rule which applies to all communications about financial products or services that refer to the environmental or sustainable characteristics of those products/services.

Additional developments on the horizon in 2024.

2024

Early 2024

Cryptoassets: HMT to introduce "cryptoassets: phase 1" secondary legislation to bring activities relating to fiat-backed stablecoins into the regulatory perimeter, subject to available parliamentary time.

2024

Review of discount rate for PI damages awards: Next review due of discount rate.

2024

Insurance intermediaries: In May 2022 the FCA wrote portfolio letters to P&CLII and LLMI on key risks and notes that they will write again in 2024 to provide their updated view of the key risks firms in this portfolio pose, the extent to which these risks are being mitigated and their updated supervisory plans.

2024

Bank of England system-wide exploratory scenario exercise (SWES): publication of the final report by the B of E, reporting on results of this exercise (launched in June 2023) to examine the behaviours of banks and non-bank financial institutions during stressed financial market conditions and identify vulnerabilities in the financial system.

2024

PRIIPS: The government intends to publish a draft statutory instrument by 2024 to enable the FCA to deliver the new disclosure regime. The FCA will publish a consultation paper on its proposed rules.

2024

Mutual insurers: Terms of reference and timeframes relating to Cooperatives, Mutuals and Friendly Societies Act are expected to get underway in early 2024.

2024

Senior Managers and Certification Regime: Consultation paper due in 2024.

2024

Vulnerable customers: As stated in the November 2023 edition of the Regulatory Initiatives Grid, the FCA intend to conduct a post-implementation review of FG21/1 in 2024 to test the effectiveness of firm's implementation and look at how this has impacted on outcomes for customers in vulnerable circumstances. It aims to publish a final report by end of 2024.

2024

ESG: FCA expected to consult on new rules for climate transition plans.

2024

Diversity & Inclusion: Following their 2023 data collection the ABI is expected to publish results of 2023 data collection and an update on the progress of its DEI blueprint.

2024

Cryptoassets: HMT to introduce "cryptoassets: phase 2" secondary legislation to bring the financial services regulation of cryptoassets within the FSMA regulatory framework, subject to parliamentary time.

2024

Multi-occupancy buildings: Legislation – Leasehold and Freehold Reform Bill – expected to be enacted which will ban managing agents, landlords and freeholders from taking commissions and other payments when they take out buildings insurance but replacing these with more transparent fees.

2024

Multi-occupancy buildings: ABI and insurance industry expected to launch reinsurance scheme designed to provide reinsurance cover for multi-occupancy buildings worst affected by cladding and other fire safety issues.

H1 2024

Insurance stress test: For life insurers the PRA aims to publish more details about their approach to the next exercise in the first half of 2024 and invite further technical input on the mechanics of the exercise, including on disclosure.

H1 2024

Funded reinsurance: New supervisory statement to come into force.

H1 2024

Insurance captives: The government expected to consult on the design of an new framework for insurance captives in the UK.

H1 2024

Post Brexit: UK and Switzerland expected to ratify Berne Financial Services Agreement

H1 2024

General insurance pricing practices: FCA expects to collect data relating to evaluation of general insurance pricing practices.

Q1 – Q2 2024

GI Pricing Intervention: FCA is having discussions with firms about a data request, with actual data collection in Q1 – Q2 2024.

Q2 2024

Solvency II (UK): Publication of 3rd consultation paper by PRA (to close in Q2 2024)

Q2 2024

Insurance branches: Final rules and policy statement due and implementation of the PRA’s proposals on authorisation and supervision of insurance branches.

Summer 2024

Change of control: new PRA supervisory statement and FCA guidance on the prudential assessment of change on acquisitions and increases in control come into force.

Dates are subject to change but the dates included in this table are correct as at the date of publication on the basis of information available to the authors.

[View source.]

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.

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