Treasury has made the Insurance Distribution (Regulated Activities and Miscellaneous Amendments) Order 2018 and laid it before Parliament on 1 May. The Order makes changes, mainly to the RAO, to reflect the changes to the regulatory perimeter consequent on IDD implementation and will fully come into force on 1 October.
The main changes generally update text to reflect or copy out relevant parts of the IDD and:
- update the “IMD override” to set out those activities that would otherwise be excluded from the need for authorisation, but in relation to which the exclusion cannot apply if the activities fall within the IDD;
- introduce new definitions for “ancillary insurance intermediary”, “insurance distribution” and “reinsurance distribution”;
- introduce a new exclusion from the arranging activity for provision of information in relation to contracts of insurance;
- update the definition of “connected contract of insurance”;
- introduce into FSMA the application mechanism for ancillary insurance intermediaries and update the relevant time periods for decisions; and
- update provisions on passporting and regulatory co-operation.