Hogan Lovells 2024 Election Impact and Congressional Outlook Report
News
UK Insurance Horizon Scanner - March, April and May 2024
01 March 2024
A snapshot of key market and regulatory developments expected to impact the UK insurance sector over the next few months.
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.
Authored by the Hogan Lovells London Insurance Team.
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