UK Insurance Horizon Scanner – April 2025 | Hogan Lovells

1 – 3 April

Motor finance: The Supreme Court heard the three linked appeals, Hopcraft, Johnson and Wrench v Close Brothers & FirstRand (the motor finance case) with the FCA intervening.

28 May

PRIIPS/Consumer Composite Investments (CCI) Regulation: Deadline for responses to the FCA’s second consultation (CP25/9) on the new CCI regime.

H1

Premium finance: FCA expects to publish an interim report following its market study and proposed next steps by the end H1 2025.

H1

Simplification of Insurance Rules (previously ‘Regulation of the commercial insurance market’): consultation paper expected on proposals, including ensuring a more appropriate balance between consumer protection and competitiveness in light of certain characteristics of the commercial insurance market, including the London market.

Q2

Liquidity reporting: Following a consultation which closed on 30 March 2025, final rules and policy on new reporting requirements for firms with the largest exposures to liquidity risks are due to be published in Q2.

Q2

Climate related risks: The PRA are expected to publish a consultation paper on updating the supervisory statement 3/19: Enhancing banks’ and insurers’ approaches to managing climate related risks.

Q3

PRIIPS/Consumer Composite Investments (CCI) Regulation: The FCA will publish its response to the feedback to its two consultation papers on replacing the PRIIPS Regulation with a new UK retail disclosure regime – the Consumer Composite Investments (CCIs) regime.

Q3

Captives regime: Government is expected to publish its response to feedback on its consultation paper.

Q3

Evaluation of general insurance pricing intervention: The FCA expects to complete its evaluation of the effect of the GI Pricing Practices rules in Q3.

4 June

Matching adjustment: Deadline for responses to the PRA’s consultation on the matching adjustment investment accelerator (CP7/25). Implementation is expected in Q4.

11 June

Friendly societies: Law Commission consultation on friendly societies as part of a review of the current law in this area, closes.

16 June

Life insurance stress test (LIST 2025): Deadline for PRA life insurance stress test 2025 submissions.

July

Motor finance: Supreme Court is expected to publish its judgment following the hearing in early April. The FCA will confirm within 6 weeks of the Supreme Court’s decision if they are proposing a redress scheme and if so, how it will be taken forward.

H2

Insurance Special Purpose Vehicles (ISPVs): The PRA’s consultation on changes to the ISPVs framework closed on 14 February 2025. Implementation of changes to the framework is expected in H2 2025.

H2

Cyber risks in the insurance sector: In its Dear CEO letter to the insurance sector, to further enhance the sector’s cyber resilience capabilities, the PRA intends to start consulting with the FCA in the
second half of 2025 on policy relating to the management of Information and Communication Technology (ICT) and cyber risks.