‘This latest consultation is another important step towards a more proportionate approach to regulating our sector,’ says senior public policy executive
The International Underwriting Association (IUA) has voiced support for the FCA’s revised proposals to simplify insurance conduct rules, calling them a “proportionate” step towards improving regulation for the London market.
In its response to consultation paper CP25/12, the IUA said the FCA’s latest proposals reflected industry feedback and recognised the unique characteristics of the London market – particularly the distinction between commercial and retail customers.
The FCA launched the consultation in May 2025 as part of its wider review to streamline its handbook and deliver smarter regulation.
It is expected to publish a final policy statement later this year.
Nafisah Hussain, senior public policy executive at the IUA, said: “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.”
She continued: “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.”
List of demands
The IUA represents 81 member firms operating in the international and wholesale insurance and reinsurance markets.
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While it backed the FCA’s announcement, it also called for greater clarity around the term ‘policyholder’ in the regulator’s new definitions, arguing this would help determine when commercial business should be excluded from certain regulatory protections.
It also raised concerns over the role of MGAs, noting that the FCA had not yet adequately reflected the position of MGAs as agents of insurers.
The association further recommended that open market risks should be treated as bespoke unless indicated otherwise, to better align with how risks are placed and underwritten in the London market.
The IUA stated that it would continue to engage with the regulator to ensure that any reforms are workable and deliver real-world benefits for market participants.

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