September 5, 2025

UK Insurance Horizon Scanner – September 2025

Hogan Lovells

+ Follow Contact

Send

Embed

Hogan Lovells

A snapshot of key market and regulatory developments expected to impact the UK insurance sector between now and the end of the year.

September	General insurance stress test (DyGIST): PRA intends to run this in 2026 (postponed from 2025). From September 2025, the PRA will engage with industry about DyGIST and provide details of logistics and they will host a workshop for participating insurers to provide logistical details and guidance.
September	Consumer duty: FCA will publish a further Feedback Statement and action plan on its proposals to simplify its consumer duty regulatory framework.
8 September	Risk Transformation regime: Deadline for responses to HM Treasury’s consultation on changes to the Risk Transformation Regulations
10 September	Non-financial misconduct: FCA consultation paper CP25/18 to align the Non-Financial Misconduct rules that apply to banks and non-banks, closes.
30 September	Premium Finance: The FCA plans to carry out further analysis including engaging with firms, industry groups, and stakeholders across the premium finance market to gather their views, and they aim to publish their final report around the end of the year. Views on any issues in the premium finance papers can be provided to the FCA by 30 September 2025.
7 October	SM&CR reform: Deadline for responses to the government’s consultation on reforming the SM&CR and the PRA and FCA consultations on improving the efficiency and effectiveness of the regime. Press release.
8 October	Insurance Linked Securities (ILS) and changes to the Risk Transformation Regulations: On 15 July 2025, the government published a consultation paper on Changes to the Risk Transformation Regulations. The consultation closes on 8 October 2025.
31 December	Liquidity reporting: Likely date for implementation of the liquidity reporting reforms for insurers. The PRA’s policy statement is awaited.
31 December	Standard formula reporting: Likely date for implementation of proposal to remove the PRA expectation for life insurers with internal models permissions to annually submit the SF.01 template containing SCR information calculated using the Standard Formula. The PRA’s policy statement is awaited.
2025	Simplification of Insurance Rules (previously ‘Regulation of the commercial insurance market’): consultation paper published May 2025 and closed July 2025 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. FCA currently reviewing comments and will publish Policy Statement – no date given.
Q3 2025	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 2025	Evaluation of general insurance pricing intervention: The FCA expects to complete its evaluation of the effect of the GI Pricing Practices rules in Q3.
Q3 2025	Distribution of Pure Protection Products: FCA intends to publish at least two papers early Q3 ahead of interim report scheduled for end 2025: (1) market overview and (2) consumer research)
H2 2025	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. The Cyber Security and Resilience Bill is due to be presented to Parliament later in 2025.
H2 2025	Insurance Special Purpose Vehicles regime: Implementation expected during H2 2025 of reforms proposed in PRA CP15/24
H2 2025	Operational incident and third party reporting: a Policy Statement is expected to be published by PRA and FCA.
Q4 2025	Matching adjustment: New framework for the matching adjustment investment accelerator due to be implemented.
Q4 2025	Life insurance stress test (LIST 2025): PRA due to publish aggregate and individual firm results.
Expected later in 2025	Managing climate-related risks: PRA Policy Statement due later in 2025 proposing updates to SS3/19 to enhance banks’ and insurers’ approaches to managing climate-related risks following CP10/25.
Expected later in 2025	Pool Re: Pool Re is expected to publish a formal response or implementation plan following their February 2025 consultation paper.
By end of 2025	Mutuals: FCA and PRA to deliver to the government a report about the mutuals landscape further to request of November 2024. Following this, the government is due to publish a Command Paper setting out its policy and strategy to support the sector.
By end of 2025	Distribution of Pure Protection Products: FCA interim report coming out of market study MS24/1 will be published.

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.

[View source.]

Send Print Report

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. Attorney Advertising.

Written by:

Hogan Lovells

Contact + Follow

less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

Increased visibility
Actionable analytics
Ongoing guidance

Learn More

Published In:

Commercial Insurance Policies

+ Follow

Consumer Insurance Products

+ Follow

Financial Conduct Authority (FCA)

+ Follow

Insurance Regulations

+ Follow

Prudential Regulation Authority (PRA)

+ Follow

Regulatory Reform

+ Follow

Reporting Requirements

+ Follow

Risk Management

+ Follow

General Business

+ Follow

Finance & Banking

+ Follow

Insurance

+ Follow

less

Hogan Lovells on:

UK Insurance Horizon Scanner – September 2025

Latest Posts

Written by:

PUBLISH YOUR CONTENT ON JD SUPRA NOW

Published In:

Hogan Lovells on:

"My best business intelligence, in one easy email…"