News

UK Insurance Horizon Scanner - January 2025

15 January 2025

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

DATE	DETAILS
1 January	Critical third parties: Final rules and policy on critical third parties set out in the joint policy statement of the PRA and FCA (PS16/24 and PS24/16) came into effect. Certain requirements are subject to a transitional period.
10 January	Commercial and bespoke insurance: Deadline for responses to the FCA’s reopened discussion paper (DP24/1).
February	Friendly Societies: The Law Commission is reviewing the legislation covering friendly societies and expects to publish a consultation paper on proposed reforms.
7 February	Insurance captives: Deadline for responses to HM Treasury’s consultation on the regulatory framework for a UK insurance captives regime.
14 February	Insurance Special Purpose Vehicles: Deadline for responses to the PRA’s consultation on changes to the ISPVs regulatory framework.
13 March	Operational incident and third party reporting: Deadline for responses to the FCA (CP24/28) and PRA’s (CP17/24) parallel consultations.
31 March	Operational resilience: Whilst insurers had until 31 March 2022 to implement the new requirements, they will then have until 31 March 2025 to demonstrate that they can keep within their impact tolerances for each important business service.
31 March	Liquidity reporting: Deadline for responses to the PRA’s consultation on liquidity reporting reforms for insurers (CP19/24).

Additional future dates to note

2025	GI pricing intervention: Completion of FCA evaluation expected in 2025.
2025	Senior Managers and Certification Regime: HM Treasury, PRA and FCA are due to publish the outcomes of the SM&CR review, which will include a commitment to consult on replacing the certification regime.

2025	Diversity & Inclusion: Following the publication of consultation papers by the FCA and PRA in 2023 (CP23/20 and CP18/23), they will prioritise the proposals on non-financial misconduct with the publication of final rules in early 2025. Policy statements on the remaining D&I proposals will follow later in 2025.
2025	Pure protection insurance: FCA will launch a market review into the distribution of pure protection insurance products. The deadline for stakeholders to provide comments on the Terms of Reference was 11 October 2024.
Q1	PRIIPS: The FCA will publish a consultation paper on repealing and replacing the PRIIPS Regulation with a new UK retail disclosure regime – the Consumer Composite Investments (CCIs) regime.
Q1	Enforcement: FCA to reach a decision about its proposals for the revised Enforcement Guide.
Q1	Consumer duty: FCA to publish a Feedback Statement following its review of whether, where and how the consumer duty requirements might be simplified.
Q1	Commercial insurance: FCA to publish a consultation paper on rules and guidance focused on ensuring an appropriate balance between consumer protection and competitiveness in light of certain characteristics of the commercial insurance market, including the London market.
Q1	Vulnerable customers: The FCA has been carrying out a post-implementation review ofFG21/1to 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 in Q1 2025.
Q1	Climate related risks: The PRA will publish a consultation paper on updating Supervisory Statement 3/19 (Enhancing banks’ and insurers’ approaches to managing the financial risks from climate change) to consolidate public feedback and reflect international standards.
Q1 2025	Life insurance stress test: For life insurers the PRA’s expectation is the first of the new stress tests will be launched in Q1 2025 with the publication in Q4 that year.
H1	Premium finance: FCA to publish an interim report following its market study and proposed next steps.
H2	Operational incident and third party reporting: FCA due to publish policy statement with final rules.
H2	Cyber risks in the insurance sector: In its Dear DEO letter to the insurance sector, to further enhance the sector’s cyber resilience capabilities, the PRA intends to start consulting with the FCA in the second half of 2025 on policy relating to the management of Information and Communication Technology (ICT) and cyber risks.

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.

Authored by the Hogan Lovells London Insurance Team.