March 2022 – Insurance Hot Topics Horizon Scanner | Hogan Lovells


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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