IUA responds to FCA’s latest insurance conduct reforms

The International Underwriting Association (IUA), which represents insurance and reinsurance companies in the London Market, has issued a response to the Financial Conduct Authority’s (FCA) latest proposals to simplify insurance conduct rules.

Representing 81 firms underwriting complex and specialist risks in the London Market, the IUA submitted a detailed response to the FCA’s consultation paper CP25/12, strongly supporting steps to reduce unnecessary regulatory burdens.

The IUA’s endorsement reflects its ongoing efforts to ensure that regulation of commercial insurance is proportionate, practical, and aligned with the unique characteristics of the London Market.

The association highlighted that many of its earlier recommendations have now been acknowledged in the revised proposals, showing meaningful engagement between the FCA and the commercial insurance sector.

Nafisah Hussain, Senior Public Policy Executive at the IUA, stated: “This latest consultation is another important step towards a more proportionate approach to regulating our sector. It recognises that the London Market is a distinct and specialist part of the insurance industry and that commercial clients should not be supervised in the same way as retail customers.

“Our members are keen to work with the regulator to ensure that the highest conduct standards remain, whilst unnecessary duplication is removed and greater flexibility is introduced. A successful conclusion to the current review will help make the London Market a more efficient and competitive environment.”

The IUA has consistently advocated for smarter regulation that protects market integrity without stifling innovation or duplicating effort. Its submission underlines that while the direction of reform is broadly welcomed, several areas still require clearer guidance and further input from market participants to work in practice.

Among the key issues raised by the IUA is the FCA’s use of the term “policyholder” in defining which commercial clients are excluded from certain consumer protections. The association urges the FCA to refine this definition to avoid confusion and ensure the rules are applied consistently across complex risk placements.

The IUA also expressed concern that the proposals do not yet fully reflect the operational role of managing general agents (MGAs), who act as authorised representatives of insurers. Clarifying how MGAs fit within the revised framework, the association argues, is essential to ensure accuracy in regulatory treatment.

Another central point in the IUA’s response is the need for open market risks to be treated as bespoke by default—unless there is clear justification to classify them otherwise. This reflects the nature of how many risks are negotiated and structured in the London Market, where customisation is the norm rather than the exception.

This website states: The content on this site is sourced from the internet. If there is any infringement, please contact us and we will handle it promptly.