New insurer authorisation process and regulatory expectations

Where to find forms

You can find all the forms you need on New Insurer Start-Up Unit.

Before submitting your application:

• Review your application to make sure you've answered all questions and included any necessary documents.
• Address any issues we discussed with you during the pre-application stage to save time later.

Important tips:

• Be honest and open with us. If we find out you've withheld information or given false or incomplete details, it will affect your application.
• Provide any other information you think we should know. If you're unsure about something, it's better to disclose it.

Inaccurate or incomplete information will delay your application.

Submitting your application

• Email an electronic copy of your application to NewInsurerStartupUnit@bankofengland.co.uk.
• If the file is larger than 25 MB, send it in multiple emails. 

What happens after submission

• We log your application and send copies to the FCA.
• We assign case officers from the PRA and FCA, usually the same people who helped you during the pre-application stage.
• Within five working days, you'll get a confirmation email from us with details about your case officers and the assessment process.

Assessment process

• We check if your application is complete and meets the necessary conditions.
• We set up monthly calls to discuss progress and any issues.
• We interview senior management and non-executive directors as required.
• We may contact you to arrange a visit.
• Within eight weeks, we'll send you the results of our assessment and request any missing information if needed.

What we will assess

We will review the following:

• Business plan and viability
• Financial resources
• Sources of funding
• Owners and controllers
• Corporate governance
• Risk management
• Customer journey
• Outsourcing
• IT systems
• Policies and procedures
• Recovery and resolution plans
• Business continuity.

For insurers under solvency II

• We will check your Solvency Capital Requirement (SCR) calculation, which is the amount of capital you need to hold.
• We will review your draft Own Risk Solvency Assessment (ORSA) report. This report assesses your risk management and solvency under normal and severe conditions.

For non-directive firms

• You don't need to calculate an SCR or produce an ORSA, but we will still review your capital, management, and governance.

Preparation tip

• Read the Index of Policy areas for insurance firms for useful guidance.

Why completeness is important

When you submit an application, we first check if it's complete. This affects how long we have to make a decision:

• Complete applications: We have a voluntary service level agreement of up to four months to assess (with a statutory timeframe to assess within six months);
• Incomplete applications: We have a voluntary service level agreement of up to ten months to assess (with a statutory timeframe to assess within twelve months).

To be complete, your application must:

• Include all required forms, fully and correctly filled out.
• Provide detailed and high-quality information.
• Address any feedback we gave during the pre-application stage.

Please see some visuals below to help you check that you have compiled and sent all the required documentation:

What do I need to send for a NISU application?

Please see the Application Checklist below:

What are the threshold conditions?

We will check if your firm meets and continues to meet the threshold conditions set by each regulator.

PRA’s threshold conditions for Insurers:

• Legal status
• Location of offices
• Prudent conduct of business
• Suitability
• Effective supervision
• Appropriate non-financial resources
• Business model

Similarities between PRA and FCA conditions: both regulators assess:

• Appropriate financial resources
• Appropriate non-financial resources

Focus of assessments:

• PRA: Ensures the safety and soundness of firms, protects insurance policyholders, and promotes competition.
• FCA: Protects consumers, maintains the integrity of the UK financial system, and promotes competition in consumers' interests.

Purpose of authorisation: Authorisation is a proactive tool to prevent harm by ensuring all regulated firms and individuals meet minimum standards from the start. We consider the type of financial services you offer and the nature and size of your customer base.

For more details, refer to the PRA’s Approach to Insurance supervision and the appendix on Threshold Conditions.

Decision timeline

• Complete applications: We have a voluntary service level agreement of up to four months to assess (with a statutory timeframe to assess within six months);
• Incomplete applications: We have a voluntary service level agreement of up to ten months to assess (with a statutory timeframe to assess within twelve months).

We aim to make a decision as quickly as possible, but this depends on how complete your application is and how promptly you respond to our requests for information. We may have questions or need more details from you during our assessment. Responding quickly and thoroughly will help speed up the process.

The decision process:

• Both the PRA and FCA will independently decide whether to authorise your insurer.
• The PRA needs the FCA's consent to authorise your insurer. Without it, the PRA cannot authorise your insurer.
• Case officers will recommend whether to approve or refuse your application, including recommendations for senior managers or other related transactions, for example waivers or modifications.

Final decision:

• If approved, you'll receive:
  • An authorisation letter
  • An independent decision-maker at each regulator will make the final decision.
  • A Scope of Permission Notice detailing your permissions and any requirements
  • A welcome pack

Your insurer's details will be added to the Financial Services Register on the date shown in the authorisation letter.

What happens if your application is not approved

1. Initial notification
• If we think we might refuse your application, we'll inform you both verbally and in writing.
• You'll have time to address our concerns.

2. Minded to refuse letter
• If you can't address the concerns, we'll send you a letter explaining why and which rules or conditions haven't been met.

3. Options
• You can withdraw your application and reapply later.
• If you want to proceed, we'll escalate your case to senior management at both regulators.

4. Warning notice
• If senior management agrees with the recommendation to refuse, you'll get a warning notice.
• You can still withdraw your application or make representations (explain your case) to the decision-makers.

5. Decision process
• Decision-makers will consider your representations.
• If they disagree with the refusal recommendation, your case goes back to the case officers for further assessment.
• If they agree to refuse, you'll get a decision notice.

6. Appeal
• The decision notice will inform you of your right to appeal to the Upper Tribunal (Tax and Chancery chamber).
• If you don't appeal, the PRA will issue a final notice, which may be published on the PRA’s website.