The Government and the regulators have taken steps to avoid or minimise disruption to financial services, including insurance, in a no deal.
The Government has legislated for a temporary permissions regime (TPR) that will allow EEA firms, including insurers, currently passporting into the UK to continue operating in the UK for up to three years after exit, while they apply for full authorisation from UK regulators and complete any necessary restructuring. The statutory instrument that implements the TPR was made law in November 2018.
Furthermore, the Government and the regulators have taken steps to ensure that any EEA contractual obligations with UK customers, including with insurance policyholders, that are not captured by the TPR can continue to be met by legislating for a financial services contracts regime (FSCR). The statutory instrument that implements the FSCR was laid in Parliament in January 2019 and has been approved by both Houses of Parliament.
However, the UK cannot unilaterally determine the conditions for UK firms' future access into the EU. A number of Member States, including Ireland, have announced measures addressing cross-border provision of financial services, including insurance, from the UK into the EU. And the European Insurance and Occupational Pensions Authority (EIOPA) issued recommendations to European regulators which seek to minimize the detriment to policyholders with cross-border insurance contracts.