Welcome to the UKGI weekly regulation update service for Aviva ABC brokers

Context

The FCA has published Consultation Paper CP26/33 proposing (for now) two minor changes to value measures data reporting and providing useful insight into the FCA’s and industry views in relation to general insurance value measures data and reporting.  The FCA introduced value measures rules in 2021, following its 2014 general insurance add-ons market study and a pilot scheme run from 2016 to 2020.  Firms report annual data on a range of value measures such as claims frequency, claims acceptance rates, average claim payouts and claims complaints, and the FCA publishes some of this data by firm and product.

The FCA has completed a post-implementation review of the general insurance value measures rules, published as part of the Consultation Paper. This review highlights data issues the FCA is tackling (for example, the inconsistencies in how firms report claims acceptance data for home insurance).  The review found the rules have improved transparency and helped firms meet fair value requirements, but reporting inconsistencies make the data harder to use and compare.

Key points to note and next actions

• The two reporting requirements that are proposed for removal are:
  • the amount that the top 2% of claim pay-outs are above; and
  • the names of firms’ five largest distribution arrangements for each product.
• The FCA proposes that these changes take effect for 2026 and 2027 data submissions on a transitional, optional basis, becoming mandatory from the 2028 reporting year (due to be submitted in 2029).
• The FCA expects to consult on wider changes to its value measures reporting rules in 2027. This may include more frequent publication of value measures data.
• The regulator has admitted it needs to improve at publishing the data on a ‘timely basis’ in future – firms provide their data by the end of February, but the FCA has not published it until July (2025), August (2023), September (2022) or October (2024).
• The FCA is inviting comments on the proposals by 9 October 2026.  Firms can respond using the online response form, or by e-mail cp26-33@fca.org.uk.
• Following this consultation, the FCA expects to consult on wider changes to the value measures rules in the first half of 2027.

Survey results

• Firms mostly use value measures in internal governance, peer benchmarking and as an input into fair value assessments, having embedded them into their own product governance frameworks.
• Feedback from stakeholders suggests value measures data has been successful in improving consumer outcomes; fewer consumers buying unsuitable general insurance products, less demand for ‘low quality’ products, and better product value.  However, certain firms reported that the data’s role had become less central since the introduction of wider fair value rules.
• Most firms polled say that value measures data helps improve transparency and competition.
• The biggest impact is felt to be from claims acceptance rates and claims complaints as a percentage of claims.
• The FCA has noted the point on multi-year products, a reason why the value measures data for GAP Insurance is perhaps skewed.
• There is reference to aligning the products reported on in value measures with those in the new complaints reporting process.
• 50% of firms say the reporting rules are unclear, leading to inconsistency in reporting amongst the (174) firms reporting this data. This led to the FCA having to query the returns of 32 of those firms.
• The FCA’s definition of a ‘claim’ is too broad – e.g., attempted claims below the policy excess, or mere enquiries from policyholders as to whether something is covered or not.
• Use of value measures data by consumer associations and the financial media has been generally low. Grouping data by insurer rather than consumer-facing brands has not helped.
• The FCA thinks AI will be accessing and using the value measures data to help inform its response to consumers’ insurance questions.  That being the case, it is perhaps vital that there is clarity in what to report, and accuracy in the published details
• The FCA will continue to engage with consumer associations to get their input – Which? and Fairer Finance were specifically mentioned.
• Geopolitical instability and related inflationary pressures may have affected claims costs and supply chains, particularly in the travel insurance sector (the value measures data for travel insurance has, in UKGI Group Consultancies’ experience, never appeared accurate).
• The FCA states that “Claims outcomes have become a greater focus for us”.
• The FCA has recognised industry issues with the differentiation between add-ons and standalone products.

Context

The FCA has confirmed that Crispin Odey’s ban from the financial services industry has been upheld by the Upper Tribunal, which found he lacked integrity.  The FCA again set out its belief that the only purpose of Mr Odey’s actions, which were subject to the FCA’s investigation and which resulted in the ban, was self-preservation and to avoid being held to account for his behaviour.

Key points to note and next actions

• The FCA’s case against Mr Odey comprised of five allegations. The Tribunal fully upheld them all and agreed that each demonstrated his lack of integrity.
• Alongside the allegations arising directly from his dismissal of his firm’s Executive Committees (ExCos), the Tribunal upheld the allegations that Mr Odey’s dealings with OAM, its clients, its investors and the FCA lacked candour. This included false assertions to and threatening behaviour towards the FCA’s staff.
• The Tribunal considered Mr Odey’s attempted justifications for removing the ExCos to be no more than a smokescreen.
• The Tribunal found that, during the trial, Mr Odey demonstrated a lack of insight into why his conduct lacked integrity, expressing no contrition for his behaviour and wrongly considering himself the victim. In multiple respects, the Tribunal found that Mr Odey’s evidence lacked credibility.
• The FCA had proposed to fine Mr Odey £1.83 million alongside the ban. The Tribunal decided to reduce this to £1.53m.

Context

The FCA has published a Final Notice cancelling Professional Liability Network’s Permission to carry out regulated activities.  The FCA stated that the firm has not been replying to correspondence and has not paid overdue fees and levies.

Key points to note and next actions

• The FCA noted its usual observations in these cases that “the firm is failing to satisfy the Suitability Threshold Condition, in that the firm is not a fit and proper person to conduct regulated activities…”
• It also appeared to the FCA that the firm is failing to meet the Effective Supervision Threshold Condition, as there was no means by which the FCA could communicate with the firm, and there was no communication from the firm with the FCA.
• The FCA explained the business has not updated its address and contact details making it impossible to “…determine whether the firm is complying with the requirements and standards of the regulatory system”.
• The firm failed to submit returns for the periods between 2 April 2025 and 31 December 2025, which were due for submission on various dates between July 2025 and March 2026.  The firm also failed to respond to the FCA in relation to overdue fees and levies.

Context

The FCA has announced that it has banned Nurul Miah, also known as Neil Mia and Neil Miah, from working in financial services.  The FCA acted after the Solicitors Regulation Authority (SRA) found that Mr Miah, who was a non-legal manager at Kingly Solicitors Limited, dishonestly caused or allowed more than £28m of client money to be taken from client accounts without permission between April 2019 and July 2020.

Key points to note and next actions

• The SRA also found that more than £10m of client money was missing and had been used by Mr Miah for his own benefit.
• Mr Miah was approved by the FCA in 2016 to work in senior management roles at an unconnected firm, Oracle Consultants Ltd.
• The FCA has concluded that Mr Miah’s actions showed he lacked the honesty and integrity needed to work in financial services. 
• The FCA has said that Mr Miah dishonestly used client money for his own benefit, that he has no place in financial services, and that the FCA has banned him to protect consumers and help maintain confidence in the financial system.

Context

The FCA has published a press release stating that small and medium sized enterprises (SMEs) could access finance more easily after the FCA sets out practical steps to help.

Key points to note and next actions

• An FCA review found no evidence that its regulation is a barrier for SMEs to access finance.
• SMEs can face barriers to accessing finance, including limited awareness of what is available, complex application forms, or a lack of suitable products.
• The FCA wants to reduce friction in this process by considering reforms to the Consumer Credit Act, and streamlining digital verification tools to improve processes where checks are needed.
• The FCA is working with the government and other regulators to address other wider issues impacting on SMEs’ ability to access finance

Context

The ICO has announced that the Government has confirmed that the ICO will become the Information Commission on 30 September 2026.  This transition is a result of the Data (Use and Access) Act 2025, which makes changes to the governance structure of the organisation, while maintaining existing regulatory functions and responsibilities.

Key points to note and next actions

• This important milestone follows the announcement in July of the seven Non-Executive Members who have been appointed to the new Information Commission Board, and who will assume their new roles on 30 September.
• Throughout this period, the ICO will remain focused on ensuring a smooth transition and continuity of service for all its customers and stakeholders.
• For further information, see The Data (Use and Access) Act 2025 (Commencement No. 9 and Transitional and Saving Provisions) Regulations 2026.

Context

The Home Office and HM Treasury have jointly announced a new £500m crackdown against money laundering, with five hundred new officers to be recruited to track dirty money, disrupt organised crime networks and seize criminal assets under a major new crackdown.  The new officers will be deployed across police forces, the NCA and the CPS to follow the money behind serious and organised crime.

Key points to note and next actions

• The NCA estimates more than £100bn is laundered through the UK or UK corporate structures each year.
• Backed by £500 million of investment over three years from the economic crime levy, the crackdown forms part of the new Anti-Money Laundering and Asset Recovery Strategy, which sets out how the UK will make it harder for criminals to hide, move, or profit from crime.
• New figures show that almost £350m of dirty money was stripped from criminals and over £1 billion denied in a year-long crackdown on dirty money.
• Twenty six million pounds was returned into the pockets of victims, 2,700 illicit finance operations disrupted and convictions for money laundering have increased to almost 4,000.

Context

The ABI has announced that the insurance and long-term savings sector is over a fifth of the way towards its commitment to invest £100 billion in UK productive assetsacross the next decade, with the latest figures confirming progress of £22.8bn since 2024.

Key points to note and next actions

• The update report published by the ABI shows £11.5bn was invested across 2025.  Annuity providers’ pledge to invest £100 billion was made following changes to the prudential regulatory regime, now known as Solvency UK, which made it easier for the insurance and long-term savings industry to invest in productive assets.
• The update report shows a number of investments made in this period, including high-quality rental and social housing for families on an average income, temporary accommodation for vulnerable residents awaiting a long-term home, education campuses, and vital water infrastructure for approximately 2.5 million people across north-west England.
• The top three sectors invested in over the first two years of the pledge are:
  • £9 billion invested in real estate, including helping to build affordable and social housing and student accommodation;
  • £5.3 billion invested in utilities, including energy and water supply; and
  • £1.8 billion invested in transport, storage and construction, including in ports, buses and rail transport

Context

In an article by Pro Global for the MGAA, Mike Dalzell, Group Head of Governance, Risk and Compliance at Pro Global, states his belief that the insurance industry’s conversation about AI is already moving on. Dalzell sets out that, for the past couple of years, much of the focus has been on generative AI: what it can write, summarise, analyse or retrieve. The more interesting development now is agentic AI: these are AI programmes that do not simply produce an answer, but can autonomously take actions, make a series of decisions and adapt what they do in response to new information.

Key points to note and next actions

• This raises some questions from a compliance perspective. A tool that helps an underwriter summarise a submission is relatively easy to place within an existing control environment.  A system that can interpret information, decide what should happen next, interact with other systems and potentially influence a customer outcome is something different.
• The risk is not necessarily that the AI gets one decision spectacularly wrong. More difficult is the possibility that a system begins to behave slightly differently from the way the organisation intended, and does so repeatedly, at scale.
• The article includes commentary on the shift in risk post-implementation, and what firms should consider doing now.
• Under the heading ‘Compliance needs to become more operational’, Dalzell states that compliance teams do not necessarily need to become data scientists, but they do need sufficiently good understanding of how an agent works to challenge the right things:
  • What objective has it been given?
  • What decisions is it permitted to make?
  • What happens when it encounters something outside its expected parameters?
  • Which decisions require human intervention?
  • How would we know if its behaviour had started to drift?

Context

A new survey by the IUA has revealed that London insurance market companies earned total premiums of £49.206bn in 2025.  The total comprised £43.658bn underwritten in London, plus a further £5.548bn classified as ‘controlled business’ overseen and managed by London operations, but written in other offices, internationally or elsewhere in the UK.

Key points to note and next actions

• Data from 80 different companies was aggregated for a new edition of the IUA’s London Company Market Statistics Report. It revealed that income for the sector was flat with the £49.206bn total representing a slight decrease of 0.1% compared to the previous year.
• The publication analyses company market premiums by class of business, placement type and geographical origin. Property is the largest class of business written in London and, with 29% of the market, is more than twice as large as the next category. Following property are liability and marine which each account for 14% of overall income.
• This year’s report also displays differing year-on-year trends for direct and facultative business compared to treaty reinsurance written in London. The former totalled £32.338bn in 2025, up 1.9% compared to 2024. Treaty contracts meanwhile fell 6% to £11.270bn in 2025.

Context

The Chartered Institute of Public Relations and Institute of Directors have jointly published a Crisis Communication Handbook for Boards, which offers practical guidance on managing the communications challenges of a crisis from start to finish.  Linked to disaster recovery planning and operational resilience, the Handbook advises Boards on how to predict, protect, prepare, respond, recover, and build enduring resilience.

Key points to note and next actions

• Designed as a practical resource for board members across sectors, the handbook examines what constitutes a crisis, the potential impact on an organisation, and best practice in communications at each stage of the crisis lifecycle.
• At 126 pages, it is a detailed and thorough document.

The handbook:

• is supported by a practical toolkit and in-depth recommendations for wider reading and practical resources;
• identifies case studies from leading academics and practitioners, examining recent and high-profile crises and the lessons they offer for Boards looking to strengthen their preparedness, upskill their personnel, and scrutinise existing plans;
• examines how the modern reputation management landscape is evolving, and with it the crisis risks which boards face; and
• sets out to address a persistent gap: while reputation is increasingly becoming a standalone discussion point on board agendas, very few boards in fact include communications professionals or understand fully the role they can play.