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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.


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.

PRA Insurance Supervision Letters

The PRA issue annual supervisory priorities statements.

Current Regulatory Issues – Overview

These are matters not addressed in the specific timelines above.

6th June 2024

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.

Read Policy Statement

23rd May 2024

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.

Read Statement of Policy

1st May 2024

FOS: Half-yearly complaints data: H2 2023

The Financial Ombudsman Service has published H2 2023 complaints data.

View FOS Complaints Data

24th April 2024

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.

Watch Webinar (On-demand)

22nd April 2024

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.

Read PRA Consultation Paper

22nd April 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.

Read Feedback Statement

22nd April 2024

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.

Read Response

18th April 2024

Speech: Promoting competitiveness is a juggling act

Speech by Sarah Pritchard, Executive Director, Markets and Executive Director, International at TheCityUK International Conference 2024.

Read Speech

15th April 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.

Read PRA Response

12th April 2024

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.

Read FCA Letter

11th April 2024

PRA Business Plan 2024/25

The PRA have published their business plan for 2024/5

Read Business Plan

19th March 2024

FCA Business Plan 2024/25

The FCA have published their business plan for 2024/5

Read Business Plan

14th March 2024

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.

Read Speech

29th February 2024

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.


Read Feedback

28th February 2024

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.

Read Policy Statement

28th February 2024

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.

Read Statement of Policy

6th February 2024

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.

Read Letter

23rd January 2024

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.

Read Consultation Paper

11th January 2024

PRA Insurance supervision: 2024 priorities

The PRA have published Insurance Supervision priorities for 2024/5

Read Letter

6th December 2023

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. 

29th September 2023

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.

Read PS23/14

3rd July 2023

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.

Read FCA Policy Statement

10th May 2023

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.

Read FCA Review

4th April 2023

FCA Business Plan 2023/24

The FCA have published their business plan for 2023/24

Read Business Plan

30th March 2023

Review of the Senior Managers and Certification Regime (SM&CR)

The FCA (DP23/3) and PRA (DP1/23) have launched a joint review of the Senior Managaers and Certification Regime. 

Read PRA Discussion Paper

25th January 2023

Consumer Duty implementation plans - FCA Multi-firm Review

FCA findings from its review of firms’ plans to embed the Duty within their businesses. 

Read FCA Review

23rd January 2023

PRA Insurance Stress Test 2022 - Results

PRA letter dated 23rd January 2023, setting out the results of the PRA Insurance Stress Test 2022.

Read PRA letter dated 23rd January 2023

10th January 2023

PRA Insurance supervision: 2023 priorities

The PRA have published Insurance Supervision priorities for 2023/24

Read Letter

10th January 2023

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.

Read PRA letter to Insurers

29th July 2022

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.

Read FCA Letter of 29th July 2022 to product manufacturers

29th July 2022

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.

Read FCA Letter of 29th July 2022 to distributors

27th July 2022

The new Consumer Duty - Policy Statement & Finalised Guidance

The FCA have issued Policy Statement PS22/9 and their Finalised Guidance for firms.

Read PS22/9 and the Finalised Guidance

25th May 2022

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.

Read FCA Letter of 25th May 2022

10th May 2022

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.

Read FCA letter to the Rt Hon Michael Gove MP

20th April 2022

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.

Read Policy Statement PS 22/3

20th April 2022

PRA Business Plan Published for 2022/23

The PRA have issued their Business Plan for 2022/23.

Read PRA Business Plan 2022/23

20th April 2022

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

Read CP4/22

7th April 2022

FCA: Strategy 2022 to 2025

The FCA have published their updated Strategy for 2022 to 2025

Read FCA Strategy

7th April 2022

FCA: Business Plan 2022/23

The FCA have published their Business Plan for 2022/23.

Read FCA Business Plan

28th January 2022

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.

Read letter

12th January 2022

PRA Insurance Supervision: 2022 priorities - Dear CEO letter

The PRA have written to all PRA-supervised firms setting out their supervisorty priorities for 2022.

Read letter

Advisory & Resourcing

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