Since December 2025 the FCA has been rewriting the insurance rulebook in stages. Some changes are already in force, some are proposals, and some are reviews with no rule yet. This tracker puts every stage in one table with its status, date and the action it requires, so brokers, MGAs and insurers can see what applies today and what to plan for.
Master tracker
| Paper | What it does | Status | Date | Main action |
|---|---|---|---|---|
| PS25/21 | Larger commercial customer and specialist risks tests replace contracts of large risks; optional single lead manufacturer (insurer or managing agent only); risk-based product review frequency; 15-hour CPD minimum removed; employers' liability notification removed | In force | 9 December 2025 | Re-map scope, record review frequencies, reset training plans |
| CP25/37 rules | PPI and packaged bank account rules removed; product governance deletions; pricing practices and value measures reporting changes; funeral plan 12-month review removed | In force | 26 June and 27 July 2026 (FCA) | Update procedures that cite deleted rules |
| PS26/6 | SM&CR Phase 1: 12 weeks to submit (not decide) senior manager applications; criminal record checks valid for 6 months; 6 months to notify responsibilities map changes; 20 working days for most Directory updates; 4 weeks for regulatory references | In force | 24 April 2026 | Update SM&CR procedures |
| PS26/6 | SMF18 at solo-regulated firms may hold any prescribed responsibility; enhanced thresholds up about 30%; overlapping certifications removed | In force | 10 July 2026 | Review allocation and certification lists |
| Financial Ombudsman Service policy statement | New dismissal grounds; amended fair and reasonable test | In force | 1 October 2026 | Update complaints handling and referral wording |
| CP26/22 | Detailed ICOBS and PROD 4 rules limited to business with a clear UK connection; duplicative disclosures removed; more digital delivery; "advice" limited to personal recommendations; PII minimums restated in sterling | Consultation closed 19 September 2026 | Policy statement date not given | Prepare a disclosure and terms of business change list |
| CP26/23 | Non-UK customers removed from the Consumer Duty; clearer reliance in distribution chains; no stand-alone board report, with board reporting at least yearly | Consultation closed 18 September 2026 | Policy statement expected Q1 2027 | Plan the 2027 board report format |
| CP26/33 | Two value measures data items removed | Consultation closed 9 October 2026 | Expected from 31 December 2026; mandatory from the 2028 reporting year | Adjust value measures data collection |
| PS26/2 | Operational incident reporting for all Part 4A firms; material third party reporting for in-scope firms | Final rules | In force 18 March 2027 | Build incident classification and reporting |
| CP25/36 | Client categorisation and conflicts of interest | Final rules expected | Q4 2026 | Watch for the policy statement |
What it means by firm type
| Change | Brokers | MGAs | Insurers and managing agents |
|---|---|---|---|
| Larger commercial customer test | Re-map which customers fall outside PROD 4 and the Duty; keep ICOBS 2 obligations | Re-map products by customer type | Re-map products; check PROD 1.4 conditions |
| Lead manufacturer option | No change: brokers distribute | Cannot be lead firm; may rely on the lead and must share information | May act as sole lead with full liability under a written arrangement |
| Risk-based product reviews | Set and record review frequency for distribution arrangements | Set and record frequency, or rely on the lead firm | Set, record and share review frequency |
| CPD minimum removed | Set training by role; keep records | Same | Same |
| CP26/23 board report proposal | Board reporting continues at least yearly, scaled to the firm's role | Same | Same |
What to do this quarter
- Close out PS25/21. Confirm every product has a recorded review frequency, every file applies the larger commercial customer test, and training plans no longer depend on the 15-hour rule.
- Check procedures for deleted rules. Remove references to PPI, packaged bank account and other rules taken out on 26 June and 27 July 2026.
- Prepare for CP26/22. List every disclosure in your terms of business and customer documents against the proposals, so changes can be made quickly when the policy statement arrives.
- Plan the 2027 board report. CP26/23 would remove the stand-alone report but keep yearly board reporting; design one report that works under both the current and the proposed rules.
- Build incident reporting. Classify operational incidents now so reporting is ready for 18 March 2027.
- Update complaints wording. Reflect the Financial Ombudsman Service changes of 1 October 2026 in complaints procedures and final response templates.
Change log
- 27 October 2026: first published, covering every paper from PS25/21 to CP26/33.
Our Consumer Duty and commercial insurance guide works through the larger commercial customer test in detail, and the PROD 4 guide for MGAs covers the lead manufacturer rules.
Frequently asked questions
From 9 December 2025 it replaced contracts of large risks with larger commercial customer and specialist risks tests, allowed an insurer or managing agent to act as sole lead manufacturer, replaced the 12-month product review with a risk-based frequency, removed the 15-hour CPD minimum and removed the employers' liability notification requirement.
No. Only an insurer or a Lloyd's managing agent with significant involvement in manufacturing the product can be the lead firm. MGAs can rely on the lead firm but must co-operate and share information.
Applying the detailed ICOBS and PROD 4 rules only where there is a clear UK connection, removing duplicative disclosures, allowing more digital delivery, limiting "advice" to personal recommendations and restating minimum PII levels in sterling.
The FCA expects to publish a policy statement and make any new rules in Q1 2027.
PS25/21 (9 December 2025), the CP25/37 rule removals (26 June and 27 July 2026), SM&CR Phase 1 (24 April and 10 July 2026) and the Financial Ombudsman Service changes (1 October 2026).
References
- FCA PS25/21: simplifying the insurance rules
- FCA: CP25/12 and PS25/21 page, including CP25/37 implementation
- FCA CP26/22: simplifying the insurance rules
- FCA CP26/23: Consumer Duty scope and proportionality
- FCA CP26/33: value measures changes
- FCA PS26/6: SM&CR review
- FCA PS26/2: operational incident and third party reporting
- FCA: Regulatory priorities, insurance report
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This article is general information as at 27 October 2026 and is not legal advice.
Definitive guides on this topic
The permanent reference pages this article relates to.