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Regulatory Timeline: Overview
Let us help you keep track of the regulatory timelines that impact your business. Our regulatory timeline looks at key announcements and deadlines for all the major FCA, PRA and Bank of England consultations affecting insurance firms, highlighting key deadlines and major milestones that have been announced, with links to the Discussion Papers, Consultation Papers, Interim and Final Reports as well as other major communications from the regulators. The summary below provides an overview of what is on the horizon, or you can delve into the detail on individual pieces of work to see the history as well as the future deadlines.
These are projects that our Directors, team and Talent Pool are involved with, advising clients and providing operational support, so we have first hand knowledge and experience of the issues for firms looking to understand, respond to and implement change resulting from each of these. We’ve included links to the Discussion Papers, Consultation Papers and Policy Statements as well as links to other relevant materials and communications released by the regulators. These are available by following the links to the specific pages from the timeline or the links shown below. If you would like to know more about how your firm should respond, please get in touch.
Consumer Duty
The regulatory work on, and scrutiny of, Consumer Duty and related work is not letting up. The Regulatory Initiatives Grid shows continual action and engagement from the FCA through to April 2025 and beyond. The rules on closed products take effect early in Q3 2024 and alongside a focus on ensuring firms have addressed their requirements for those products, it is very clear that the FCA will not be letting up in their market oversight work on Consumer Duty generally.
Culture
A Consultation Paper on the SMCR reforms is expected in H1 2024 and that will give more detail on how the regulators propose adapting the regime to deliver on the objectives. The Discussion Paper was a single paper, published by the PRA on behalf of itself and the FCA. Both regulators had independently conducted earlier reviews of SMCR. But set against the backdrop of this review being undertaken as part of the much-talked-about Edinburgh reforms, it is a reasonable assumption that some 5+ years since insurers (2018) and intermediaries (2019) became subject to SMCR, we are likely to see change now. That is unlikely to take effect before 2025.
The FCA separately required London Market firms to provide data on non-financial misconduct matters by 5th March and whilst no timeline was given for how and when it might respond to the data provided, given that request included a requirement for the data to separate out incidents involving Senior Management Function holders, it seems likely that the expected Consultation Paper on SMCR will also at least touch on non-financial misconduct.
Operational Resilience
Under the most recent update from the FCA on 7th December 2023, firms are now also expected to report material operational incidents to the FCA. Examples would include situations that:
- result in a significant loss of data;
- result in the unavailability or control of your IT systems;
- affect a large number of customers; or
- result in unauthorised access to your information systems.
The FCA and PRA have created a cyber resilient self-assessment questionnaire, CQUEST, this consists of multiple-choice questions covering aspects of cyber resilience, such as:
- Does your firm have a Board approved cyber security strategy?
- How does it identify and protect its critical assets?
- How does it detect and respond to an incident, recover the business, and learn from the experience?
- The PRA sees cyber-related risks as a major emerging threat to firms and in that context firms can be expected to have considered cyber-related operational threats as part of their Operational Resilience planning more generally. It is one of the key issues highlighted by Sam Woods in his foreword to the PRA plan.
The FCA has also created a broader operational resilience self-assessment questionnaire called ORQUEST to help firms understand their operational resilience capabilities, including their cyber capabilities.
Distribution and The Insurance Distribution Directive
The Insurance Distibrution review in its initial form commened with an FCA discussion paper in March 2017. Final handbook rule changes were confirmed in May 2018. Since then, the Lloyd’s market has implemented its own review of practices to determine whether further regulatory work is required and the FCA have continued to look at the effectiveness of implementation of individual elements as part of its review of Conduct Risk, including Product Governance, Customer’s Best Interests and annual training requirements. There are links with the work on General Insurance Pricing Practices and Vulnerable Customers which firms should be conscious of.
General Insurance Pricing Practices
This should now be a ‘BAU’ process for most firms, with the reporting of required data at the appropriate deadlines now embedded in processes but the FCA statement from September 2023 indicates that the FCA has continuing concerns about the effectiveness with which the rules have been implemented. With a review of the data ongoing and an update promised in 2025 firms cannot yet treat this work as BAU. Firms should expect to be asked some difficult questions if the data suggests the rules on pricing have not been implemented as expected.
There are links with the work on Consumer Duty, Distribution and Vulnerable Customers which firms should be conscious of.
Vulnerable Customers
The FCA work on Vulnerable Customers started in July 2019. Finalised Guidance was issued in February 2021 and firms should by now have implemented any required changes, ensuring they are able to undertake the monitoring and evaluation of outcomes for vulnerable customers that the FCA require.
There are links with the work on Consumer Duty, General Insurance Pricing Practices and Distribution which firms should be conscious of.
FCA Supervisory Portfolio Strategy Letters
The FCA have grouped firms as members of portfolios of firms that share a common business model. The portfolio strategy letters below set out their view of the main risks of harm in each portfolio and the actions the FCA expect firms to take as well as providing guidance on what the FCA will be doing to reduce the level of harm in that sector.
- FCA Personal and commercial lines insurance portflio letter: Insurance Market Priorities 2023-2025 (20th September 2023)
- FCA Wholesale insurance portfolio letter: insurance market priorities 2023-2025 (20th September 2023)
- FCA Life insurance portfolio letter: insurance market priorities 2023-2025 (20th September 2023)
- FCA Supervision Strategy for Lloyd’s & London Market Insurers and Others (LLM). (28th September 2021)
- FCA Supervisory Strategy for Life Insurers (5th August 2021)
- FCA Supervisory strategy for Personal and Commercial line insurers (28th April 2021)
- FCA Supervision Strategy for Lloyd’s & London Market Insurers and Others (LLM) (23rd November 2020)
- FCA supervision strategy for Price Comparison Websites (PCWs) (16th November 2020)
- FCA Supervision Strategy for Lloyd’s & London Market Intermediaries and Managing General Agents (LLMI) (3rd November 2020)
- FCA Supervision Strategy for Personal and Commercial Lines Insurance Intermediaries (4th September 2020)
- FCA Supervision Strategy for Personal and Commercial Lines Insurance Intermediaries (4th September 2020)
- Portfolio strategy letter to firms in the Personal & Commercial Lines Insurer (PL&CL) portfolio: identifying and remedying harms (8th January 2020)
- Risks Life Insurance firms pose to consumers or markets (6th December 2018)
PRA Insurance Supervision Letters
The PRA issue annual supervisory priorities statements.
- PRA Insurance Supervision: 2024 priorities (11th January 2024)
- PRA Insurance Supervision: 2023 priorities (10th January 2023)
- PRA Insurance Supervision: 2022 priorities (12th January 2022)
- PRA Insurance Supervision: 2021 priorities (15th December 2020)
Current Regulatory Issues – Overview
These are matters not addressed in the specific timelines above.
TR24/2: General insurance and pure protection product governance thematic review
The FCA has published TR24/2: General insurance and pure protection product governance thematic review
General insurance value measures data 2023
The FCA has published the general insurance value measures data for 2023
FCA Call for Input: Review of FCA requirements following the introduction of the Consumer Duty
The FCA has published a ‘Call for Input’ with a review of FCA retail conduct rule requirements following the introduction of the Consumer Duty.
DP24/1 - Regulation of commercial and bespoke insurance business
The FCA has published a Discussion Paper on the Regulation of commercial and bespoke insurance business.
PS13/24 – Funded Reinsurance
The PRA has published Policy Statement PS13/24 on Funded Reinsurance.
PRA Dear CEO Letter: Funded reinsurance: Implementation approach
The PRA has issued a ‘Dear CEO’ letter providing insights gained from the consultation process and explain how it expects firms who use Funded Reinsurance to assess their practices against the expectations set out in the Supervisory Statement.
PS10/24 – Review of Solvency II: Reform of the Matching Adjustment
The Prudential Regulation Authority has its Policy Statement on the reform of the Matching Adjustment.
The PRA approach to insurance branch authorisation and supervision
The Prudential Regulation Authority has published its Statement of Policy on its approach to insurance branch authorisation and supervision.
FOS: Half-yearly complaints data: H2 2023
The Financial Ombudsman Service has published H2 2023 complaints data.
FCA Webinar: Overseeing your Appointed Representatives
The FCA has hosted a webinar aimed at Principals, providing an update on the AR regime and how it is using data to inform its supervisory approach. It also shared some findings from its current work.
CP5/24 – Review of Solvency II: Restatement of assimilated law
The PRA has published its final consultation needed to implement the conclusions of the Solvency II Review. The deadline for feedback is 22nd July 2024.
FS24/1 Potential competition impacts from the data asymmetry between Big Tech firms and firms in financial services
The FCA has published its Feedback Statement and responses to the Call for Input (CFI), asking for focused information and evidence on whether any data asymmetry between Big Tech firms and financial services firms could influence how effectively competition evolves in financial services markets.
FCA response to the Government’s White Paper on Artificial Intelligence
The FCA has published its response to the Government’s White Paper on Artificial Intelligence.
Speech: Promoting competitiveness is a juggling act
Speech by Sarah Pritchard, Executive Director, Markets and Executive Director, International at TheCityUK International Conference 2024.
PRA: Solvency II Review – Matching adjustment reform implementation considerations for 30 June 2024
The PRA has responded to clarifications requested by firms in their responses to its consultation paper ‘Review of Solvency II: Reform of the Matching Adjustment’, and to assist relevant insurance firms to prepare for implementation of the matching adjustment reforms in a way that makes efficient use of resources and allows firms to make the most of new investment opportunities facilitated by the reforms.
FCA Dear CEO Letter: "Action Needed: maintaining adequate financial resources"
The FCA have written to all firms requesting that they immeidately begin work to assess the adequacy of their financial resources. The letter was issued in the context of the ongoing investigation into historical motor finance commission arrangements, but has been address to all firms.
PRA Business Plan 2024/25
The PRA have published their business plan for 2024/5
FCA Business Plan 2024/25
The FCA have published their business plan for 2024/5
Speech: Investing in outcomes: a regulatory approach to deliver for consumers, markets and competitiveness
Speech by Nikhil Rathi, FCA Chief Executive delivered at the Morgan Stanley European Financials Conference.
PS3/24 – Review of Solvency II: Reporting and disclosure phase 2 near-final
The PRA have provided feedback to responses to consultation paper (CP) 14/22 – Review of Solvency II: Reporting phase 2 as well as Chapter 7: Reporting and disclosure in CP12/23 – Review of Solvency II: Adapting to the UK insurance market.
PS2/24 – Review of Solvency II: Adapting to the UK insurance market
This policy statement provides the PRA’s feedback to responses received to certain parts of Consultation Paper CP12/23 published in June 2023.
The PRA’s approach to insurance group supervision
The PRA have published a statement of policy (SoP) setting out their approach to certain aspects of insurance group supervision under the Group Supervision Part of the PRA Rulebook.
FCA Letter: Notice to provide information in relation to incidents of non-financial misconduct
The FCA have written to firms requesting information related to incidents of non-financial misconduct as part of a sector-wide information gathering exercise. All regulated Lloyd’s Managing Agents & London Market Insurers (including P&I Clubs) and Lloyd’s and London Market Insurance Intermediaries (and Managing General Agents) are required to respond.
CP2/24 – Solvent exit planning for insurers
The PRA have published proposals for PRA-regulated insurers to prepare for an orderly ‘solvent exit’ as part of their business-as-usual activities and to be able to execute a solvent exit if needed.
PRA Insurance supervision: 2024 priorities
The PRA have published Insurance Supervision priorities for 2024/5
FCA Webinar - Consumer Duty: The next steps
The FCA hosted a webinar on 6th December 2023 to help firms understand the next steps for Consumer Duty.
FCA confirms leasehold buildings insurance reforms
The FCA has confirmed new measures to support leaseholders in the multi-occupancy buildings insurance market with the publication of PS23/14: Multi-occupancy building insurance Feedback to CP23/8 and final rules.
PS23/9: Finalised insurance guidance on supporting customers in financial difficulty’
The FCA have published their Policy Statement and Finbalised Guidance on Customers in Financial Difficulty.
FCA Report - Consumer Duty: Findings from our review of fair value frameworks
The FCA have published the findings of their review into firms’ approaches to fair value assessments under the Consumer Duty.
FCA Business Plan 2023/24
The FCA have published their business plan for 2023/24
Consumer Duty implementation plans - FCA Multi-firm Review
FCA findings from its review of firms’ plans to embed the Duty within their businesses.
PRA Insurance Stress Test 2022 - Results
PRA letter dated 23rd January 2023, setting out the results of the PRA Insurance Stress Test 2022.
PRA Insurance supervision: 2023 priorities
The PRA have published Insurance Supervision priorities for 2023/24
PRA Insurance supervision: 2023 priorities
PRA letter dated 10th January 2023, setting out its priorities for the supervision of life and general insurers in 2023.
Product Governance and Fair Value - General Insurance and Pure Protection
FCA letter to product manufacturers setting out its concerns over the new rules on fair value introduced 1st October 2021.
Product Governance and Fair Value - General Insurance and Pure Protection: Expectations for distributors
FCA letter setting out its concerns over the new rules on fair value introduced 1st October 2021.
The new Consumer Duty - Policy Statement & Finalised Guidance
The FCA have issued Policy Statement PS22/9 and their Finalised Guidance for firms.
Dear Board of Directors Letter: FCA Supervisory Strategy for Personal & Commercial Lines Insurance Intermediaries (P&CLII)
FCA letter setting out its concerns over a number of issues. Firms are requested to consider the extent of these risks in their businesses and act where they identify harm.
Multi-occupancy Building Insurance - FCA Response To Michael Gove
The FCA has responded to the Rt Hon Michael Gove MP providing an update on their work looking into the issues.
FCA: PS22/3: Diversity and inclusion on company boards and executive management
The FCA have issued their Policy Statement on Diversity and Inslusion. This applies to UK and overseas issuers with equity shares, or certificates representing equity shares, admitted to the premium or standard segment of the FCA’s Official List.
PRA Business Plan Published for 2022/23
The PRA have issued their Business Plan for 2022/23.
PRA: CP4/22 Regulated fees and levies: Rates proposals 2022/23
The PRA have issued their proposals for regulated fees and levies for 2022/23
FCA: Strategy 2022 to 2025
The FCA have published their updated Strategy for 2022 to 2025
FCA: Business Plan 2022/23
The FCA have published their Business Plan for 2022/23.
PRA "Dear CEO" Letters: Insurance costs for multi-occupancy buildings
The PRA have written to insurers and intermediaries involved in the placement of insurance for multi-occupancy buildings. Their focus is on distribution costs and ensuring products provide fair value with premiums that fairly and accurately reflect risk.
Letters have been written to Insurers and Intermediaries.
PRA Insurance Supervision: 2022 priorities - Dear CEO letter
The PRA have written to all PRA-supervised firms setting out their supervisorty priorities for 2022.
