August 31, 2022

Insurance Horizon Scanner – September and October 2022 edition

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

Month	Date	Expected development
September 2022		Financial Services and Markets Bill: PRA is due to publish a discussion paper on how it will implement the proposals in the Bill.
	5	Data: Second reading of the Data Protection and Digital Information Bill in the House of Commons.
	7	Financial Services and Markets Bill: The Bill will have its Second Reading in the House of Commons.
	28	Stress test (IST 2022): Firms’ due to submit technical information. The stress test is to establish the ability of the UK’s largest insurers to withstand a major cyberattack or natural disaster. See: PRA stress testing website and Dear CEO letter.
October	11	Insurance Special Purpose Vehicles: Deadline for responding to PRA consultation paper CP10/22 on changes to the PRA approach to authorising and supervising ISPVs.
	22	Funeral plans: Transitional period ends for unauthorised funeral plan providers to wind down.
	28	Mutual insurers: The Co-operatives, Mutuals and Friendly Societies Bill has its second reading in the House of Commons.
	28	Future UK-EU relationship: Deadline for submitting evidence in response to the House of Lords European Affairs Committee inquiry into the future UK-EU relationship.
	31	ESG - UK Stewardship Code 2020: Deadline for applications to become a signatory to the Code which sets standards for those investing money on behalf of UK savers and pensioners and those supporting them.
	31	New Consumer Duty: The Boards of firms should have scrutinised and approved implementation plans.

Additional developments on the horizon

Season/quarter		Expected development
H2 2022		Law Commission project on conflict of laws and emerging technology: This new project is expected to begin in the second half of 2022.
H2 2022 - 2023		New legislation outlined in the Queen’s Speech to be introduced to Parliament: Transport Bill – introducing new laws on self-driving and remotely operated vehicles and vessels.
Q3 2022		ESG: FCA due to publish FCA TCFD report on enhancing their role facilitating sustainability in financial firms and markets.
Q3 2022		Diversity: FCA/PRA to consult on diversity in financial services.
Q3/4 2022		ESG: FCA due to issue consultation paper on prudential ESG disclosures.
Q4 2022		Climate change: According to PRA report on climate-related financial risk management and the role of capital requirements the BoE will put out a "call for papers" and host a climate and capital conference in the fourth quarter of 2022. Informed by these steps and internal analysis, the BoE will publish a follow-up report on the use of capital, including a plan on how future scenario exercises after CBES might guide further work on capital.
Q4 2022		Climate change: Financial Stability Board consultation on supervisory and regulatory approaches to climate-related risks. FSB recommendations will be reported Q4 2022.

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.