Professional & Financial Services

Insurance and pension compliance checklist

A confirmation checklist for insurers, reinsurers and occupational pension schemes. Work through the duties every business in this division shares, then the section for what you operate — answer only the items for the activities you actually carry on.

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Confirm the obligations that apply to your business are in place. Start with section 1, which applies to every insurer, reinsurer and pension scheme operator, then complete the section for what you operate. Where a duty differs by nation, the item says so.

Section 1 — Every insurance and pension business

  1. 1

    Protect personal data and pay the ICO fee

    Handle policyholder, claims and member data — much of it special category — under the UK GDPR; unless exempt, register with the ICO and pay the annual data protection fee. UK-wide.

  2. 2

    Insure your employees

    At least £5 million employers' liability cover from an authorised insurer if you employ anyone (Great Britain; equivalent rules in Northern Ireland).

  3. 3

    Manage workplace health and safety

    Protect employees and others in your offices and call centres under the Health and Safety at Work etc. Act 1974 (Great Britain; corresponding order in Northern Ireland).

  4. 4

    Assess fire safety

    Carry out and maintain a fire risk assessment of your non-domestic premises (Fire Safety Order in England and Wales; separate regimes in Scotland and Northern Ireland).

  5. 5

    Avoid discrimination

    Comply with the Equality Act 2010 (Great Britain) or Northern Ireland equality law in employment and in services to the public.

Section 2 — Insurers and reinsurers

A pure reinsurer is a business-to-business firm — skip the Consumer Duty, pricing, promotions, complaints and FSCS items, but you must still pay claims within a reasonable time (the Insurance Act 2015 covers reinsurance contracts) and complete the rest.

  1. 1

    Hold Part 4A permission as a dual-regulated firm

    Effecting and carrying out contracts of insurance — including pure reinsurance — are PRA-regulated activities; authorisation is PRA-led with FCA consent. Carrying on insurance business without authorisation is a criminal offence. UK-wide.

  2. 2

    Meet the Solvency UK prudential standard

    Hold capital, governance and PRA reporting to the Solvency UK regime; if you write life business, also maintain the long-term fund protections.

  3. 3

    Meet operational resilience requirements

    Identify important business services, set impact tolerances and stay within them — a joint FCA and PRA regime.

  4. 4

    Operate the SM&CR

    Senior managers pre-approved (PRA functions by the PRA, conduct functions by the FCA), certification staff assessed annually, conduct rules embedded.

  5. 5

    Deliver the Consumer Duty on retail business

    Fair value, customer understanding and outcome monitoring across your retail products (Principle 12).

  6. 6

    Keep financial promotions compliant

    Every promotion fair, clear and not misleading under the s.21 FSMA restriction and the Financial Promotion Order.

  7. 7

    Handle complaints under DISP and pay claims in reasonable time

    DISP time limits and final responses with FOS referral rights; claims paid within a reasonable time (Insurance Act 2015 s.13A); proportionate remedies applied to fair-presentation breaches.

  8. 8

    Price home and motor insurance fairly

    No price walking — renewal prices must not exceed the equivalent new business price (FCA general insurance pricing rules).

  9. 9

    Participate in the FSCS

    Belong to the Financial Services Compensation Scheme and pay its levies.

Section 3 — Occupational pension schemes

  1. 1

    Register with The Pensions Regulator

    Register the scheme, keep registrable information current and complete the annual scheme return; master trusts need TPR authorisation. UK-wide.

  2. 2

    Meet the DB funding regime

    Statutory funding objective, funding and investment strategy, actuarial valuations and recovery plans for defined benefit schemes.

  3. 3

    Satisfy trustee knowledge and understanding

    Trustees hold and maintain the knowledge of pensions and trust law, and of the scheme's own documents, that the Pensions Act 2004 requires.

  4. 4

    Connect to pensions dashboards

    Connect to the dashboards ecosystem in line with the staged timetable and by the regulatory connection deadline, and return members' data (Pensions Dashboards Regulations 2022).

  5. 5

    Keep the scheme qualifying for automatic enrolment

    If employers use the scheme for automatic enrolment, maintain minimum contribution levels and the DC default fund charge cap.