May 5, 2023

UK Insurance Horizon Scanner - May and June 2023 edition

Hogan Lovells

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Hogan Lovells

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

MAY	8	Solvency II reporting review (phase 2): consultation on PRA’s proposals to streamline reporting and disclosure requirements (CP14/22) and on the Insurance Taxonomy published in the public working draft release note, closes. Implementation date is likely to be for quarterly and annual reference dates falling on and after 31 December 2024.
	10	FCA Discussion Paper on Finance for Positive Change: comments due.
	17	Operational resilience: CTP to the UK financial sector: FCA survey closing date.
JUNE		Solvency II: first consultation paper expected.
	1	Senior managers and certification regime: Deadline for responses to the FCA/PRA joint discussion paper on operational aspects of the SM&CR DP1/23 – review of the SM&CR and to HM Treasury’s Call for Evidence which covers legislative aspects of the regime.
	7	Digital currency: HMT and BoE Consultation on a UK central bank digital currency (A digital pound) closes.
	9	Multi-occupancy buildings insurance: FCA CP23/8 closes.
	30	ESG Data and Ratings: HMT consultation on regulatory regime for ESG ratings providers closes.
	End of June 2023	Data collection: Joint (BoE, FCA and industry) programme to transform data collection: BoE and FCA due to publish their recommended solutions (Phase 1 recommendations).
	June/July 2023	Insolvency arrangements for insurers: final rules and policy anticipated. PRA’s consultation on CP3/23 ‘Dealing with insurers in financial difficulties’ closed on 31 March.
	April – October 2023	Travel insurance: FCA intends to conduct their post-implementation review of their travel signposting rules – this will have been delayed by one year.

Additional developments on the horizon for H1 and Q2 2023

	H1 2023	Entry of Big Tech: The FCA aims to publish a Feedback Statement.
	Q2 2023	Customers in financial difficulty: FCA aiming to publish final Policy statement (with guidance coming into force in July 2023).
	Q2 2023	Digital: Law Commission plans to publish a consultation paper in relation to the current rules on private international law as they may apply in the digital context and, if appropriate, make recommendations for reform to ensure that the law in this area remains relevant and up to date.
	Q2/3 2023	Operational resilience: PRA/FCA consultation paper to be published on incident and outsourcing and third-party reporting.

Dates are subject to change but the dates included in this table are correct as at the date of publication.

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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.