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

Context

The FCA has published Quarterly Consultation Paper 51 – CP26/8.  There is one item of note for our clients (see Chapter 4 and Appendix 3) in relation to making a correction to a change made in error in SYSC 1.5.3R in PS25/3 (the CCR009 Consumer Credit Returns Policy Statement) and to make minor amendments to SUP 16 to correct discrepancies in the wording used in the Consumer Credit Returns.

Key points to note

• The changes at SYSC 1.5.3R (4)(a) and 5(a) are unlikely to be relevant to our clients, as they relate to a minor wording change in the section headed “Definition of a significant SYSC firm”.
• The Consultation contains, in paragraph 4.10 on page 21, a table outlining which sections in the CCR009 return (i.e., which data fields) are subject to corrections to minor discrepancies in the wording used. None of these affect the meaning of the data fields, but the FCA is proposing to align the wording. The changes to the questions listed in the table cover:
  • adding the product/section name to the question itself to make them clearer when completing the form
  • using more consistent wording/options across sections to avoid potential misunderstanding; and
  • spelling mistakes/incorrect cross referencing.
• Some examples of the above are (words struck through are current Handbook words being removed, and words underlined are proposed new text):
  • “Please provide us with the following information:
  • “114A-W – Total For motor vehicles on credit agreements, total number of introductions made by your firm (excluding activity of your appointed representatives, if you have any)”
  • “203A    If you have selected ‘’W – Other reason’’, then please specify why you have you not used your debt adjusting and/or debt counselling permission.?”
  • 222A-M – Total For debt solutions offered and administered by your firm, total revenue for your firm (excluding activity of your appointed representatives, if you have any) of derived from commission per debt solution type”
  • “Section 2.4.4: Debt solutions offered by your firm via appointed representatives but administered by another firm via appointed representatives”
• The FCA invites comments on this Consultation paper, and comments should reach the FCA by 13 April 2026 for Chapter 4.  Comments may be sent by electronic submission using the online response form on the FCA’s website, or by emailing cp26-8@fca.org.uk.

Context

The FCA has updated its Events web page with details of a “Working together to fight financial crime” conference in London on 14 May from 8.30 am to 6.30 pm.

Key points to note and next actions

• The event “…brings together leaders from across regulation, industry, law enforcement, government, technology and professional bodies for a day that’s all about practical insight, collaboration and system wide impact.”
• Please note that availability is subject to demand.

Context

The FCA has published its response to the Complaints Commissioner’s report in relation to Amyma Limited, sympathising with those who lost money in investments promoted by Amyma.  The FCA includes its usual response that it has carefully considered the Complaints Commissioner’s findings.

Key points to note and next actions

In summary, the FCA:

1. Does not agree with the Commissioner’s findings about its actions in relation to Amyma in 2017 (Element One).
   The FCA disagrees with the Commissioner’s finding that it acted unreasonably in closing its 2017 enquiry into Amyma. It says it stepped back to avoid interfering with another agency’s investigation, had limited reports about wider misconduct, and had to prioritise resources given over 13,000 reports were received in that year. It maintains its decision was reasonable.
2. Does agree in some respects with the Commissioner’s findings about the FCA’s handling of the Approved Persons applications connected to Amyma’s appointment as an Appointed Representative (AR) (Element Two) in 2018.
   The FCA says it should have reviewed Amyma’s Approved Persons applications more closely, but it could not block the Principal firm from appointing Amyma as an AR. Oversight of the AR was the Principal’s responsibility, and FCA follow‑up did not lead to termination.
3. The FCA agrees with the Commissioner’s findings in relation to compensation (Element Three), which the Commissioner did not uphold.
   Consumers harmed by an Appointed Representative should complain to the Principal firm, and if unhappy with the outcome, they can escalate to FOS or the FSCS.

The FCA is strengthening the AR regime due to consumer harm caused by poor oversight from Principal firms. This includes supporting HM Treasury’s 2026 reform proposals, the introduction of stricter rules in 2022 to improve Principals’ oversight and data reporting, and reviewing AR notifications alongside Approved Persons applications to better target higher‑risk firms.

Context

The PRA has imposed a financial penalty of £10,625,000 on U K Insurance Limited (UKI Limited) in connection with a miscalculation of their Solvency II balance sheet during 2023 and 2024. This resulted in UKI Limited overstating its solvency to the PRA and to the market.

Key points to note and next actions

• UKI Limited, is a subsidiary and principal underwriter of Direct Line Group (DLG), and now part of Aviva plc. 
• The miscalculation arose due to ineffective preventative and detective controls and resourcing issues in its finance and actuarial functions. It went undetected by DLG’s internal controls for a significant period of time.
• Following identification of the miscalculation, DLG made a Regulatory News Service announcement acknowledging the miscalculation and the knock-on effect on the reported SCR Coverage Ratio, and reported the correct figure.
• DLG’s senior management notified the PRA without delay, undertook detailed investigations to ascertain the root cause of the error and remediated the position.
• The PRA permitted UKI Limited to participate in the Early Account Scheme (EAS) and the firm made early admissions and agreed to resolve the matter, thereby qualifying for a 50% enhanced reduction in the amount of the financial penalty which otherwise would have been £21.25m.
• This case is a landmark enforcement outcome for the PRA as it is the first in which the EAS has been used. 

Context

FOS is urging young drivers across the UK to make well-informed decisions when taking out car insurance. With many young people getting behind the wheel for the first time, it is vital they understand what to look for in a policy and how to avoid common pitfalls.

Key points to note and next actions

• FOS is calling on young drivers to avoid common pitfalls with their car insurance.
• Drivers are advised to make sure they understand what their policies cover.
• FOS reminds people that it can help resolve issues directly with their car insurance provider.

Last year the FOS received over 1,200 car insurance complaints from drivers under 25. The top three issues were cancellations of policy, followed by administration or customer service problems and claim related complaints including delays in settling claims.  FOS has identified issues that can affect car insurance policies and sometimes premiums which newer drivers may not be aware of. These include undeclared car modifications, concerns over telematics devices, and ‘fronting’ – where a more experienced driver, such as a parent, claims to be the main driver of the vehicle that is mainly used by a younger, less experienced driver.

Context

The ICO has announced that its new interactive self-service tool to help firms decide if they are making a restricted transfer under UK GDPR is now live.  The self-service tool will provide customised guidance on how the legislation is likely to apply to firms’ specific transfer scenarios.  The ICO uses ‘transfer’ in this tool to refer to both sending personal information to a separate organisation outside the UK, and making personal information accessible to a separate organisation outside the UK.

Key points to note

The tool is based on a three‑part test which helps firms work out whether their situation counts as a restricted transfer, including:

1. whether the UK GDPR applies to the information;
2. whether you are sending it to an organisation outside the UK; and
3. whether that organisation is a separate legal entity.

There are up to six questions to answer, and the process takes about ten minutes.  Although the results of the tool are not definitive (the ICO stresses that it is still a firm’s responsibility to make sure its processing complies with UK data protection law), it provides a reliable indication of how the legislation is likely to apply.

Context

The OFSI and the FDCA have published an overview of the UK Government’s approach to enforcing breaches of UK sanctions. This follows the cross-government review of sanctions implementation and enforcement, which concluded that, ‘a cross-government strategy on enforcement will assist industry to understand the range of non-compliance and possible enforcement consequences’.

Key points to note

• The document sets out key enforcement principles, emphasises the importance of strong compliance and outlines the potential consequences of non-compliance.
• It also summarises the roles of key government departments, regulators and enforcement bodies.

Context

The Government has published its new Fraud Strategy for 2026–29, setting out its latest plans to strengthen the UK’s approach to tackling fraud.  The ABI has published its response to the new Strategy.

Key points to note and next actions

• The ABI states its belief that “fraud is the biggest crime in England and Wales”, with millions of people affected by it each year, often those in the most vulnerable circumstances.
• The ABI fully supports the Government’s drive for a united approach to crack down on fraud and welcome the Strategy’s focus on partnerships alongside continued investment in public awareness and victim support.
• The ABI acknowledges that the tech sector has made some progress, and the increased focus on this area will be crucial to help tackle the issue. With most fraud starting online, tech firms, social platforms and telecoms providers must now deliver on their commitments and contribute to prevention and detection, and the strengthened governance framework to monitor their performance is welcome.
• Insurers already invest heavily in fighting fraud and take this threat extremely seriously. The ABI will continue working closely with Government to implement the strategy and deliver on the Fraud Charter to strengthen the UK’s resilience.