New Insurer Start-up Unit – frequently asked questions

Please see the Application Fees area of New Insurer Start-up Unit which provides links to the FCA Fees guidance covering both PRA and FCA fees that will need to be paid.

The PRA will advise you whether your submitted Application passes the Completeness test or not.

• 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 would encourage firms to work closely with us during the pre-application stage to ensure firms prepare their applications as thoroughly as possible and of high-quality content, which will enable the process to run more smoothly during the formal application process. Please refer to New insurer authorisation process and regulatory expectations for the application checklist to ensure you prepare and send all required documentation.

Please refer to Senior Managers Regime: how to apply and ensure that you download and attach an application Form A as part of your Senior Manager applications.

Note that firms are expected to complete their full due diligence ahead of submitting these applications, including confirmation of regulatory references (and/or standard employment references) have been completed. And we require confirmation that a criminal records check has been run (dated within three months of the submitted application).

Please ensure that all directorships (active and inactive) are fully disclosed. This will help us to process your application more quickly

Please ensure you submit the relevant forms for your firm application:

• Owners and influencers appendix (DOC)
• Owners and influencers appendix: notes (DOCX)
• Corporate controllers form (DOCX)
• Partnership controllers form (DOCX)
• Individual controllers form (DOCX) 

Don’t forget to provide the percentage share for each controller and close links to associated firms. And ensure that all directorships (active and inactive) are fully disclosed. This will help us to process your application more quickly.

Firms must provide a comprehensive and up-to-date management responsibilities map (‘MRM’) that describes its management and governance arrangements.

This includes overseas firms which must supply a comprehensive and up-to-date MRM that describes the management and governance arrangements for any branch it maintains in the United Kingdom.

MRMs must include:

• details of the reporting lines and the lines of responsibility; and reasonable details about:
  • the persons who are part of those arrangements; and
  • their responsibilities.

Please refer to the full set of requirements in PRA Rulebook Insurance - Allocation of Responsibilities and FCA SYSC 25.2.3R.

Please visit the page Insurance | Bank of England for all PRA policies covering capital, governance (including risk management and controls), operational resilience, reporting and disclosure, Groups, Lloyd’s, Insurance Special Purpose Vehicles and Third Country branches of international insurers.

Please visit the pages below for more information:

How to apply for authorisation or registration | FCA 
Insurance sellers and authorisation | FCA 

The mandatory Senior Manager Functions typically include SMF1 Chief Executive, SMF2 Chief Finance and SMF9 Chair of the Governing body (although there may exceptions, for instance, smaller firms may use SMF25 to cover these roles). Firms may refer to the PRA Rulebook sections below for further guidance:

• Insurance – Senior Management Functions (Solvency II)
• Non-Solvency II Firms – Senior Management Functions

These sections define which SMFs are required for each firm type and provide the legal basis for their implementation under the PRA’s regulatory framework.

Depending on size, firms may be required to have additional or other SMFs. Please see some further guidance below which may be useful for your particular firm’s governance model (although the onus is on firms to review and decide what is appropriate for their particular model):

• We would generally expect to see large SII and large Non-Directive Firms (NDFs) to have the following Senior Manager functions:  SMF4 (Chief Risk), SMF16 (Chief Compliance), SMF17 (Money Laundering Reporting Officer (MLRO)) and SMFs relevant for Chairs of committees applicable to the firm.
• For larger insurers, SMF5 (Head of Internal Audit) may be applicable unless outsourced. 
• Small run-off firms operate under a lighter regime where SMF1 (Chief Executive)/ SMF26 (Other Overall Responsibility), SMF2 (Chief Finance), and SMF21 (EEA Branch Senior Manager), if with-profits, which may be applicable.
• Small NDFs could also use the SMF25 "Small Insurer Senior Management Function" function, when a senior individual has overall responsibility for one or more aspects of a firm’s affairs that are not otherwise covered by another specific SMF.
• For larger firms, note that SMF7 is required where individuals at group have significant control/influence. And branches are normally required (by minimum) to have an SMF19 (Head of Overseas Branch).

Please find a link to SS35/15 – Strengthening individual accountability in insurance.

Under the UK’s Senior Managers and Certification Regime (SM&CR), insurance firms must carefully assess and document conflicts of interest and time commitments for senior manager candidates, particularly when applying for FCA or PRA approval. Here's how firms should approach this:

1. Conflicts of interest

Firms must:

• Identify and assess any actual or potential conflicts of interest a candidate may have, especially where they hold multiple roles or external directorships.

• Maintain a conflicts of interest policy, as outlined in SYSC 10.1 of the FCA Handbook 1, which includes:

• Types of conflicts relevant to the firm’s business
• Procedures for managing and mitigating conflicts
• Disclosure requirements where conflicts cannot be avoided.

• Ensure that conflicts do not compromise the integrity or independence of the individual’s decision-making.

2. Time commitments

Firms must:

Evaluate whether the candidate has sufficient time to perform their SMF role effectively. Firm should consider:

• The number and nature of other directorships or roles held
• The complexity and scale of the firm’s operations
• Any geographical spread or regulatory obligations.

Provide a detailed explanation in the application (Form A), justifying how the candidate can meet the time demands of the role.

Best practices

• Include a time commitment statement in the candidate’s statement of responsibilities
• Keep a record of board minutes or nomination committee discussions that assess the candidate’s capacity and conflicts
• Regularly review and update these assessments, especially if the individual takes on new roles.

The UK Corporate Governance Code and the Senior Managers and Certification Regime (SM&CR) are complementary frameworks that together promote accountability, transparency, and effective leadership in UK financial services, including insurance firms.

Please refer to the UK Corporate Governance Code 2024 – FRC (effective for financial years starting on or after 1 January 2025). Here are some ways in which the Code supports the SM&CR:

1. Board leadership and accountability

• The Code emphasizes clear division of responsibilities between leadership roles (e.g., Chair and CEO), aligning with SM&CR’s requirement for clearly defined responsibilities through statements of responsibilities.
• It supports the SM&CR’s goal of personal accountability by requiring boards to ensure that individual directors understand their roles and are held accountable for their performance.

2. Composition and capability

• The Code requires boards to have the right mix of skills, experience, and independence, which aligns with SM&CR’s fitness and propriety requirements for Senior Management Functions (SMFs).
• It also encourages ongoing evaluation of board effectiveness, supporting the SM&CR’s annual reassessment of SMF holders.

3. Risk and internal control

• The Code’s focus on robust risk management and internal controls complements the SM&CR’s emphasis on reasonable steps by senior managers to prevent regulatory breaches.
• Provision 29 of the 2024 Code (effective from 2026) requires boards to declare the effectiveness of material internal controls, reinforcing SM&CR’s accountability standards.

4. Culture and conduct

• Both frameworks stress the importance of corporate culture. The Code encourages boards to align company values and strategy, while SM&CR enforces conduct rules that apply to all staff.

5. Transparency and reporting

• The Code’s “comply or explain” approach promotes transparency, which supports SM&CR’s requirement for firms to document and disclose how responsibilities are allocated and managed.

The PRA cannot authorise a branch in the UK unless the parent has been authorised by the home state supervisory authority in the home jurisdiction. While in principle it is possible for us to assess the branch application while the home state supervisory authority is assessing the application for the parent to be authorised in the home jurisdiction, firms should think carefully about the sequencing of these applications and only apply for the branch to be authorised once the parent has been fully authorised in the home jurisdiction or it is highly probable that it will be authorised by the home state supervisory authority. The PRA will endeavour to provide a decision on a new branch application within a maximum of 1 year. If a branch application is made and it is unlikely that the parent will be authorised within 1 year, it is likely the PRA will have to reject the branch application. 

Please visit PRA to accelerate authorisations for UK Insurance Special Purpose Vehicles.