Continental Europe primed to adopt Consumer Duty type rules as ‘alignment between regulators’ gains prominence

Regulators overseeing insurance markets in Continental Europe are increasingly opting to follow the UK’s lead and learnings, with market participants signposting that the FCA’s Consumer Duty regulation is likely to be mirrored and introduced in jurisdictions such as France.

The FCA first introduced Consumer Duty in July 2023, with the rules designed to set higher and clearer standards of customer protection.

For example, the outcomes focused regulation requires firms to measure, analyse and benchmark their performance across a number of metrics designed to bolster service – including products and services, fair value, consumer understanding and consumer support.

Speaking exclusively to Insurance Times, outgoing Covéa Insurance chief executive Georges De Macedo – a native Frenchman employed by Paris-headquartered Covéa Group, Covéa Insurance’s parent company – explained that Continental Europe is watching with interest the “very specific regulatory focus” that oversees UK general insurance (UKGI).

He feels this is because the UK’s approach to industry-wide oversight “will probably become the new norm in Continental Europe” – specifically with regards to Consumer Duty linked processes, such as firms’ ability to identify areas of improvement and evidence positive change.

He explained: “The UK market is very different from the French market and other markets. The UK market is very specific in some regards and there is a lot of regulatory pressure or regulatory focus. I believe that this, at some point, will probably become the new norm in Continental Europe.

“It’s quite interesting for me to see this in the UK and anticipate this type of thing [happening] in France, for instance.”

De Macedo added that some of the challenges faced by UK insurance customers that the FCA has sought to mitigate through Consumer Duty “will become relevant in France” – meaning that its financial services regulator, Autorité de Contrôle Prudentiel et de Résolution (ACPR), will “have to deal” with similar “root causes of some issues raised by some customers”.

He continued: “It’s really this Consumer Duty aspect, making sure that we have this continuous improvement process to make sure we improve the service that we provide to customers. And not just to say it, but to evidence it. This is the challenge that Consumer Duty brings to us.

“From my perspective, Consumer Duty is more about evidence [and having] the ability to identify areas where improvements [need to be made] and take actions quickly to resolve that.”

Greater global regulatory alignment

Currently, the ACPR oversees the French insurance market using regulatory tools such as the French Insurance Code, European Union directives and consumer rights focused legislation Hamon Law, effective from 2014.

However, according to De Macedo, there is not an equivalent regulation that calls for evidence of good customer outcomes in the same way as the UK’s Consumer Duty rule.

Current Covéa Insurance chief executive Xavier Laurent added: “The UK has always been regarded as the model, as the most developed insurance market. The Consumer Duty regulation makes sense coming from the UK to protect the insured. The British market is really competitive.”

Zurich UK chief executive Drazen Jaksic – who spent a year leading the insurer’s Benelux business, encompassing Belgium, the Netherlands and Luxembourg, from December 2023 – agreed with De Macedo’s take that Continental Europe could copycat UK insurance regulation.

He commented: “All the regulators around Europe are working together and collaborating. It’s a question of time because we will see more alignment between the regulators.

“Wherever [firms] operate, [they] just need to adjust the way [they] operate. [While] some might consider [the UK’s] regulation a little bit more complex and demanding, it also provides a lot of protection for consumers.”

Market changes and considerations

However, Jaksic warned that there are key market differences that any insurance focused regulation would need to consider.

For example, the Benelux region’s insurance sector is more the size of the UK’s mid-market, with Belgium and the Netherlands being “obviously smaller”, “more fragmented” and “predominantly driven by local insurance brokers” versus what is considered the norm in the UK.

In addition, the Netherlands has “one of the most mature MGA markets in Europe, outside of the UK”, Jaksic said.

Considering global geographies are seemingly looking to the UK’s regulatory landscape as a leader of the pack, it will be interesting to see how the FCA’s recent deregulation focus potentially filters through into Europe too – although this is, in part, linked to repetition between Consumer Duty and prior rules.

For example, on 9 December 2025, the regulator confirmed that it will remove the mandatory 15-hour continuing professional development requirement, as well as eliminate the governance requirement to review products every 12 months.

Graeme Reynolds, director of competition and interim director of insurance at the FCA, said: “We’re simplifying and removing rules for insurers and brokers, reducing regulatory costs and helping them focus on delivering better outcomes.

“Our focus on smarter regulation is not once and done and by using the Consumer Duty, we’ll continue to look at rules we may no longer need. We want firms to keep engaging with us on further simplifications for the insurance sector, so we can support growth and innovation.”