November 2, 2022

Insurance Horizon Scanner – November and December 2022 edition

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 couple of months.

NOVEMBER 2022		Financial Services Regulatory Grid: Financial Services Regulatory Initiatives Forum to publish latest version of its Regulatory Initiatives Grid.
		Diversity: FCA/PRA to consult on diversity in financial services – they plan to provide a further update on timing in the next Regulatory Initiatives Grid, which is expected to be published in November.
	4	Law Commission project on smart contracts and digital assets: Deadline for Law Commission consultation on provisional law reform proposals to ensure the law recognises and protects digital assets: digital assets project
	4	Financial Services and Markets Bill: The Public Bill Committee is due to report on 4 November 2022
	8	Appointed Representatives: New FCA rules aimed at making authorised financial firms more responsible for their appointed representatives come into effect. HM Treasury are reviewing the responses to its Call for Evidence on the Appointed Representative regime to identify possible future reforms through legislative changes.
	23	Operational Resilience/Critical Third Parties: Closing date for responses to the joint PRA and FCA Discussion Paper 22/3 on potential ways to manage the systemic risk posed by certain third parties.
	30	Insurance Special Purpose Vehicles: PRA expects to implement changes to the authorisation and supervision of ISPVs by this date, or one week after the publication of final rules.
DECEMBER 2022		Appointed representatives: FCA plans to issue a Section 165 data request in December 2022. Firms will have 60 days to respond.
	8	Appointed representatives: The rule changes and enhanced notification requirements take effect.
	8	PRA: Discussion Paper DP4/22 on future approach to policy, open for comments until 8 December.
	23	Critical Third Parties: Deadline for responses to the PRA and FCA joint Discussion Paper (DP22/3) on ways to manage the systemic risks to their objectives posed by third parties.

Additional developments on the horizon for 2022

Q4 2022		Climate change: Financial Stability Board consultation on supervisory and regulatory approaches to climate-related risks. FSB recommendations will be reported Q4 2022.
END OF 2022		Climate change: Technical Screening Criteria to define what economic activities are environmentally sustainable is to be finalised by end-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.