May 31, 2022

March 2022 - Insurance Hot Topics Horizon Scanner

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

Month	Date	Expected development
June 2022	17	Dormant Assets: FCA's consultation on expansion of the dormant assets scheme to cover insurance, pension and securities firms closes. The FCA expects to finalise its rules in July 2022.
	30	Climate change: Financial Stability Board consultation on supervisory and regulatory approaches to climate-related risks – consultation period ends. FSB recommendations will be reported Q4 2022.
	30	PRICL: PRICL project expected to end 30 June 2022.
July 2022		Dormant Assets: FCA expects to finalise its new rules on the expansion of the dormant assets scheme to cover insurance, pension and securities firms.
	21	Solvency II: Consultation period closes on HM Treasury's proposals for reform to the Solvency II regime and on the PRA's discussion paper (DP 2/22) on changes to the risk margin and matching adjustment. See our article: HM Treasury and PRA start the consultation process on the UK’s Solvency II regime).
	29	Funeral plans: providers and intermediaries of prepaid funeral plans become regulated by the FCA.
August 2022		Solvency II: Additional Solvency II sustainability requirements come into force.

Additional developments on the horizon:

Season/Quarter	Expected development
H1 2022	ESG: FCA to begin stakeholder engagement relating to promoting well-designed, well-governed credible and effective transition plans.
	Law Commission project on conflict of laws and emerging technology: This new project is expected to begin in the first half of 2022.
Mid 2022	Law Commission project on smart contracts and digital assets: It is expected that the digital assets project will not be completed until the middle of 2022.
H2 2022 - 2023	Regulatory reform: Financial Services and Markets Bill to be introduced to Parliament. The Bill will implement the results from the Future Regulatory Framework Review, the Solvency II review and new consumer protections.
	New legislation outlined in the Queen's Speech to be introduced to Parliament: Data Reform Bill – introducing a new data protection framework. Transport Bill – introducing new laws on self-driving and remotely operated vehicles and vessels.
	Insolvency/Resolution: amendments to the insolvency arrangements for insurers to be introduced to Parliament when time allows. Proposals for a Resolution Regime for insurers to be announced in due course.
Q3 2022	ESG: FCA due to publish FCA TCFD report on enhancing their role facilitating sustainability in financial firms and markets.
	Appointed representatives regime: following the consultation which closed 3 March 2022, the FCA plans to publish final rules in Q3 2022. HMT will decide whether amendments to FSMA are required once it has considered responses to its Call for Evidence which also closed on 3 March 2022.
	Diversity: FCA/PRA to consult on diversity in financial services.
	New Consumer Duty: FCA expects to publish policy statement with final rules and guidance.
Q3/4 2022	ESG: FCA due to issue consultation paper on prudential ESG disclosures.

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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.