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

Context

The FCA has updated its Supercharged Sandbox web page to announce that applications are now open for Cohort 2 of its Supercharged Sandbox.  The Supercharged Sandbox is a cohort-based programme designed to help firms experiment, test and develop AI use cases in financial services. It provides firms with a secure, controlled environment to experiment with advanced AI technologies.

Key points to note and next actions

Participants operate within a secure cloud environment, with access to graphics processing unit (GPU)-enabled infrastructure, high-quality datasets and expert support, helping them to develop and test AI solutions rapidly.

The programme is designed to help firms:

• Develop and test innovative AI-driven solutions.
• Build evidence and understanding through experimentation.
• Accelerate the journey from concept to deployment.  

Context

In what might be seen as an unusually strong approach, the FCA is launching a review of the claims management market, following concerns that consumers are being failed by some claims management companies (CMCs) and law firms.  This is the latest measure by the regulators to improve standards in this market. A joint taskforce was announced in March to tackle poor handling of motor finance claims by some CMCs and law firms. 

Background

• The FCA has removed or amended 800 misleading adverts, more than 28,000 consumers have been able to exit contracts free of charge, and three CMCs reduced their unreasonable fees, protecting over 500,000 consumers. Formal investigations are also underway, with one announced by the FCA.
• The Solicitors Regulation Authority (SRA) regulates around 9,000 law firms in England and Wales. As of 30^th April 2026, it has 109 open investigations relating to 76 firms that manage high-volume consumer claims. It has also closed seven firms working in this area.

Key points to note and next actions

• The review will look at the root causes of poor practices across the market, like aggressive marketing, misleading advertising and unfair exit fees.
• Other concerns include consumers being signed up without their consent (without clear, upfront explanations of the implications of signing up or ticking a box, for example on social media adverts) or by multiple representatives, potentially causing confusion and delaying compensation.
• Working in close collaboration with the SRA and other regulatory partners, the FCA will “rigorously examine”:  
  • Whether consumers receive fair value, including competition on price and quality, and whether existing price caps are still fit for purpose, especially where free-to-use redress mechanisms exist.
  • Financial incentives, including fee structures, funding and insurance arrangements, and whether these create conflicts of interest and/or lead to poor conduct and outcomes.
  • Whether the full end-to-end consumer journey, including lead generation, marketing and advertising, delivers good consumer outcomes.
  • Whether different approaches across different regulatory regimes affects firm behaviour and if some firms are failing to secure the appropriate permissions.  
• The FCA will look at practices of firms it regulates, including lead generators, as well as those authorised by others – working with its regulatory partners.  
• The FCA expects “…full, prompt and open cooperation from all parties we engage in the review”.  The FCA has said that it will take robust action if this is not forthcoming.  
• Where it believes legislative change is needed, the FCA will make recommendations to Government, or relevant bodies, including whether CMCs and law firms should be subject to stronger compensation mechanisms if they cause harm.

Context

The FCA has announced that, following the publication of financial reporting by PayPal Holdings Inc, it is investigating Mastercard, PayPal and Visa under Chapter I in the Competition Act 1998, and Mastercard and Visa under Chapter II in the Competition Act 1998, for suspected anti-competitive conduct linked to the funding and usage of PayPal’s digital wallet.  The FCA has pointed out that it has reached no conclusions nor made any findings about competition law having been broken.

Key points to note and next actions

• At this stage, this appears to be no more than the FCA announcing that the investigation is happening.
• The FCA is currently gathering evidence. The FCA may proceed to issue a statement of objections setting out its provisional view that there has been an infringement of the law. Not all cases result in the FCA issuing a statement of objections. If the FCA ultimately proceeds to issuing a statement of objections, it will provide the addressee(s) of that statement of objections with an opportunity to make written and oral representations, before it makes a final decision on whether the law has been broken.
• The Competition Act 1998 prohibits agreements, practices and conduct that may damage competition in the UK.
• The Chapter I prohibition in the Competition Act 1998 prohibits agreements, concerted practices and decisions by associations of undertakings which have as their object or effect the prevention, restriction or distortion of competition within the UK or a part of it, and which may affect trade within the UK or a part of it unless they are excluded or exempt.
• The Chapter II prohibition in the Competition Act 1998 prohibits conduct which amounts to the abuse of a dominant position in a market, and which may affect trade within the UK.
• The powers and processes that the FCA has and follows in relation to the Competition Act 1998 are separate and different from those followed in relation to enforcement of the Financial Services and Markets Act 2000. Further detail on the FCA’s procedures in CA98 cases is available in our CA98 guidance.
• Competition Act 1998 cases may also be brought by the Competition and Markets Authority.

Context

All insurance intermediaries have today, 7 May 2026, received an unexpected RegData submission request from the FCA. This is not malicious; it is a genuine request. However, the FCA did not announce to the market that this request was coming, and the e-mail firms received this morning is somewhat lacking in detail, so it has caused a degree of concern from some quarters – but the request is actually a very simple one, requiring a single tick-box answer.

Background

In February, the FCA published a ‘Regulatory Priorities Report’ (RPR) for the insurance sector in which it sets-out its main priorities for 2026-27 which are:

• Improving consumer understanding, claims handling and service quality;
• Increasing access to insurance;
• Supporting growth and innovation; and
• Simplifying regulation.

The RPR tells firms what actions the FCA is planning to take for each of these priorities, and what it expects/encourages firms to do in response. The RPR is the regulator’s new method of disseminating its areas of focus to firms in each financial sector, instead of issuing ‘Portfolio Letters’ which was its previous methodology. The RPR will be published annually in future.

Key points to note and next actions

To ensure firms are taking their regulatory responsibilities seriously, the FCA is asking you to tick a box on RegData to acknowledge the notification and to confirm that the RPR has been distributed to the ‘appropriate stakeholders and senior leadership’ in each firm. Below is a screenshot of the RegData request:

As with all new RegData returns, only the firm’s Principal User can access this return. In fact, only the Principal User will have received the email notification that this return is due. If you’re not the Principal User for your firm, there are two options that can be taken to grant you access to this return:

1. The Principal User can log-in to RegData (via the ‘My FCA’ portal) and ‘assign access’ to any other user/users.
2. An Admin User can log-in to RegData (via the ‘My FCA’ portal) and grant access to any other user/users. (However, that Admin User cannot assign access to themself! Another Admin User would need to do that.)

Once submitted, you will be presented with a green confirmation box on the screen. Please ensure this appears before you log-off the system:

The return must be submitted by 4 June at the latest to avoid a financial penalty from the FCA. Therefore, if you have any issues accessing the new return, please speak to your usual UKGI contact for assistance.

We are aware that firms are receiving an e-mail, having completed the attestation, confirming that it has been submitted but, for some reason, showing an incorrect time stamp.

Context

The Home Office and the MoJ have jointly updated the GOV.UK web page in relation to the Crime and Policing Act 2026 (‘the Act’), following it receiving Royal Assent on 29 April 2026.  The Act makes a provision for corporate liability (so making the business itself responsible) where a senior manager commits an offence while acting in the scope of their actual or apparent authority, for all crimes.

Background

The Economic Crime Corporate Transparency Act 2023 (ECCTA) contains provisions in relation to corporate responsibility for offences committed by senior managers, but that responsibility is limited to ‘economic crimes’.  The ECCTA addressed shortcomings in corporate liability laws in a significant number of cases, but the then government acknowledged during the passage of the ECCTA that wider reform was required to introduce corporate liability for all crimes.  Those ECCTA provisions are now, therefore, replaced and considerably widened by the new provisions in the Act. 

Key points to note and next actions

• The bill adopts the definition of ‘senior manager’ as provided in the Corporate Manslaughter and Corporate Homicide Act 2007. This definition looks at what the senior manager’s roles and responsibilities are within the organisation – the level of managerial influence they might exert – rather than their job title. It covers instances where the senior manager is a person who plays a significant role in the making of decisions about the whole or a substantial part of the activities of the body corporate. 
• This has the advantage of providing greater clarity on the parameters of the legal test and will also bring the law up to date to reflect modern company structures where directing minds are spread across different functions of a business. It will enable prosecutions to progress in more cases where senior level employees who do exert decision making power are found to be involved in the offending.
• All firms need to be aware of this development, and should review their internal policies and check their PII cover and any D&O (or similar covers) they have in place.
• For insurance firms, this is an issue to consider when (for intermediaries) renewing business and corporate insurances for clients, and (for insurers) when reviewing policy wording and contract coverage.

Context

The ASA has published details of an ‘upheld’ Ruling in relation to two paid-for Meta (Facebook) ads for a training accreditation company which made misleading comparative claims with identifiable competitors which weren’t supported by evidence and could not be verified by consumers.  The Ruling forms part of a wider group of investigations on companies offering Continuing Professional Development (‘CPD’) accreditation services.

Firms seeking accreditation of their training (either in-house or services they provide) should ensure that appropriate due diligence is carried out in relation to any potential accreditation body.

Key points to note and next actions

• Two issues were investigated, both of which were Upheld.
• The first ad included the text “Join thousands of learning and training providers who’ve future-proofed their business with CPD accreditation […] CPD accreditation from the UK’s leading body can help you” followed by bullet points that stated, “Validate your expertise”; “Win more corporate and B2B contracts” and “Stand out in a crowded market”.  It included a video in which a CPD adviser spoke to the camera about CPD and referred viewers to a free guide on how to “sense check” their training.
• The second ad included the same text as ad (a).  Additional text stated, “GROW your TRAINING BUSINESS”. Smaller text near the bottom of the ad stated, “Discover how CPD accreditation can open doors to new opportunities” and included a call to action that stated, “DOWNLOAD TODAY!”.
• The CPD Register Ltd challenged the claim “UK’s leading body” in ads (a) and (b) for being misleading, asking whether it could be substantiated and was verifiable.

Context

EIOPA has issued a public consultation on its draft technical advice on minimum common standards for insurance guarantee schemes (IGS) in the European Union. The advice, which includes a detailed technical annex, comes in response to a request from the European Commission.

EIOPA is to provide its final technical advice to the European Commission by 31 August 2026. Article 98 of the Insurance Recovery and Resolution Directive requires the Commission, after having consulted EIOPA, to submit a report to the European Parliament and the Council on the suitability of establishing minimum common standards for insurance guarantee schemes within the European Union.

In line with most recent FCA publications, EIOPA believes that the proposals represent a balanced, proportionate and effective approach – in line with broader efforts to simplify regulation and reduce administrative burdens.

Key points to note and next actions

• Insurance policyholders across the EU face differing levels of protection when insurers fail. This is explained by a patchwork of national schemes that vary widely in scope and coverage—as well as the absence of such schemes altogether in some countries. This, across member states, has led to significantly different outcomes for policyholders after failures, particularly in cross-border cases.
• It is against this backdrop that EIOPA sets out its draft technical advice. The proposals address four main policy areas:
  • general questions about the impact of minimum harmonized IGSs
  • operational functioning of IGSs
  • conditions for effective funding of IGSs and
  • interaction between the IRRD and harmonized IGSs.
• For each of these areas EIOPA analysed several policy options and, where possible, presented a preferred option.
• Responses can be made online.

Context

Latest ABI data shows home insurers paid out £846 million in property claims across the first quarter of 2026, helping thousands recover from unexpected events. 

Key points to note and next actions

• The average household claim was £6,340 which is the highest on record, and up 20% compared to the same period last year.  
• Extreme weather continues to take its toll. Claims payout can vary significantly depending on the time of year and, at an average of £6,040, this is the highest first-quarter average on record – up 38% compared to the same period last year when it was £4,390.
• The average household subsidence claim has risen 9% from £16,295 in 2025 to £17,820 in the first quarter of 2026.
• Home insurers paid out £4,350 for the average theft claim this quarter, a 14% increase from last year’s average of £3,800.
• Home insurance payouts accounted for over half (57%) of property payouts in this period, with a total of £1.5 billion in claims paid.
• Premiums fell for a fourth consecutive quarter. The average combined premium is now 5% (£22) lower than the same period last year when it was £396. Average buildings‑only premium is £306, a 6% (£19) decrease compared to the same time last year. Contents‑only cover averaged £117, 12% (£15) cheaper year-on-year. 

Context

The CII has announced that it will join the Injury Prevention Consultancy (IPC) in its campaign to protect performers and crew members across film, television and theatrical production.  The professional body will host a roundtable of London Market stakeholders to consider ways to help the creative sector raise its game on safety standards.

Key points to note and next actions

• Contributions from the discussion with underwriters, brokers and claims professionals will help shape the IPC’s Impact of Injury 2026 (IOI26) report. The report will, in turn, drive up standards with guidance on targeted injury prevention models and policies.
• Nearly 80% of cast and crew members working in stage or screen productions have been injured at some point in their careers, according to research into ‘the human toll and economic impact of injury’ laid out in the IPC’s 2025 report. The report highlighted a lack of preventative measures, worsened by a culture of fear in which workers are scared to speak up when they feel in danger.
• IOI26 will provide an updated, industry-wide view of progress, challenges and priorities for action, examining the repercussions of injury on workers, production timelines, insurance claims, and long-term workforce retention.