News

UK Insurance Horizon Scanner 2026

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

DATE (2026)

DETAILS

1 January

Berne Financial Services Agreement: The Agreement came into effect and firms may now register to use the Berne Financial Services Agreement.

27 January

Simplifying FCA insurance rules: Deadline for responses to CP25/37: Targeted clarifications of Handbook materials. Proposals cover clarifications on rules and guidance. Changes will come into force immediately upon publication of a policy statement in Q2.

2 February

Conflicts of interest: Deadline for responses to the FCA’s CP25/36 published on 8 December 2025. Includes proposals to rationalise the rules in SYSC 10 and SYSC 3.

6 February

Alternative life capital: deadline for responses to the PRA’s DP2/25 – Alternative life capital: supporting innovation in the life insurance sector.

February/March

Motor Finance commission review: following the FCA consultation (closed on 12 December 2025), if the FCA decides to introduce a redress scheme, a policy statement, final rules and launch of the scheme are expected in early 2026.

4 March

Solvency II reporting and disclosure: deadline for response to the PRA’s consultation (CP22/25) on post-implementation amendments. Changes to take effect for year end 2026 reporting requirements.

Q1

GI value measures post-implementation review by FCA: stakeholder engagement and data collection. Publication of results of the review due in Q3.

Q1

Distribution of Pure Protection Products: FCA intends to publish an interim report of its findings from its market review together with a full consumer research report.

Q1

Premium Finance Market Study: Following publication of the FCA’s updates to its Market Study paper setting out its initial findings, the FCA is due to publish its final report early in 2026.

Q1

Friendly Societies: The Law Commission is due to publish its final recommendations following its review of the friendly societies legal framework in early 2026.

Q1

Digital Markets, Competition and Consumers Act 2024: FCA will consult on changes to the FCA Handbook to reflect the Act. *

Q1

Sales processes: FCA to carry out an analysis on how different sales processes affect customer outcomes. *

April

Consumer Composite Investments (CCI) Regulation: Start of the transition period from PRIIPS to the new CCI regime.

May

General insurance stress test (DyGIST): PRA to launch the test. The exercise will simulate a series of adverse events over a three week period.

30 June

Solvent exits: Rules on preparation for a solvent exit come into force.

Q2

Consumer Duty: Policy statement due following consultation on clarification of rules and guidance (CP25/37).

Q2

Third country branches: Following CP20/25, the PRA will publish a policy statement and final rules to address identified inconsistencies across various areas of reforms, streamline the policy framework, clarify expectations for branches, and increase the indicative subsidiarisation threshold for branches (which will come into effect upon publication of the policy statement). Remaining updates will come into effect at year end 2026.

Q2

Sales processes: FCA to start its review of how travel and home insurance firms are acting to improve consumers’ understanding of their cover, and share best practice with industry. *

Q2/3

Captive insurance: PRA/FCA expected to consult on new rules for a new captives regime – implementation expected in mid-2027. HM Treasury is consulting on legislative amendments to allow captives to be established via Protected Cell Companies.

Q2/3

Claims handling: the FCA will amend the scope of its planned outsourcing oversight work to include different delegated models and remuneration arrangements. It will also carry out an analysis of claims services quality to focus on home and travel insurance. *

H1

Consumer Duty: FCA to publish a formal consultation on updates to the Consumer Duty. This reviewing historic non-Handbook material, and issuing a supervisory statement and consultation on the Consumer Duty scope and distribution chain issues.

H1

Incident and Outsourcing and third party reporting: a Policy Statement and final rules are expected to be published by PRA and FCA. Implementation will be 12 months later.

H1

Simplifying FCA insurance rules: FCA to publish an update on its simplification work following the consumer duty requirements review.

Mid 2026

Senior managers and certification regime: following the publication of policy statements and final rules by the FCA and PRA, the implementation of the first phase of reforms is likely to b in mid-2026.

 

Climate-related risks: new requirements on managing climate-related risks came into effect on 3 December 2025 and insurers have 6 months in which to transition to the updated expectations.

Q3

GI value measures post-implementation review by FCA: Publication of results of the review due.

30 September

Liquidity reporting: implementation of the liquidity reporting reforms for insurers.

December

General insurance stress test (DyGIST): aggregate industry level results due to be published.

31 December

Third country branches: remaining policy and reporting changes for third country branches come into effect.

31 December

Solvency II reporting and disclosure: Changes to take effect for year end 2026 reporting requirements.

During 2026

Mutual insurers: Following the publication of the joint FCA and PRA mutuals landscape report in December 2025, the PRA will publish guidance on the consolidation process (Part VIII transfers), the FCA will start work on legacy issues in the life and pensions market with a view to reducing regulatory burdens. The government is due to publish a Command Paper setting out its policy and strategy to support the sector.

 

Risk Transformation Regulations: On 15 July 2025, the government published a consultation paper on Changes to the Risk Transformation Regulations. The consultation closed on 8 October 2025. No timeframe yet given for publication of the Government’s response. The PRA is working with HMT on further reforms to the insurance ISPV framework.

 

Cyber risks in the insurance sector: HM Treasury and the PRA intend to consult on policy relating to the management of information and Communication Technology (ICT) and cyber risks. A consultation paper is planned for 2026.

 

FSCS general insurance limit review: the PRA is considering the responses to the discussion paper published in 2023.

* FCA action in response to Which?’s super-complaint about the consumer outcomes in home and travel insurance.

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.

 

Authored by the Hogan Lovells London Insurance team.

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