October 6, 2023

UK Insurance Horizon Scanner - October, November and December 2023

Hogan Lovells

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Hogan Lovells

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

MONTH	DATE	DETAILS
OCTOBER	9	Insurance Distribution Directive (UK): closing date for responses to the FCA’s consultation on changes to the FCA Handbook to incorporate requirements currently in the IDD EU Delegated Regulations which currently form part of retained EU law.
NOVEMBER	28	Entry of Big Tech into financial services market: FCA holding expert panel event.
DECEMBER		GAP insurance: In September 2023, the FCA announced told firms manufacturing GAP insurance products they must take immediate action to prove customers are getting a fair deal, or it will intervene – giving firms a three-month ultimatum.
	5/6	Mesothelioma: Court of Appeal hearing on two cases considering the state of knowledge and foreseeability of risk of injury in claims involving exposure to asbestos before 31 October 1965 (Cuthbert v Taylor Woodrow and White & others v Sec of State for Health and Social Care)
	6/7	Entry of Big Tech into financial services market: FCA holding sector specific workshops
	8	Appointed Representatives Regime: Deadline for principals to have carried out their first annual review of appointed representatives.
	18	Diversity & inclusion: closing date for responses to the PRA’s consultation paper on diversity and inclusion in PRA-regulated firms (CP18/23). New rules and expectations will come into effect one year following publication of final rules.
	End of 2023	Solvency II (UK): legislation to reform the risk margin and matching adjustment expected to come into force.
	2023/2024	Vulnerable customers: The FCA intends to evaluate what action firms have taken and whether it has seen improvements in the outcomes experienced by vulnerable customers in 2023-24. At the same time, it will look again at how the financial services industry is adapting to meet the needs of older customers.

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.

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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.