Key takeaways

• The Bank of England and Financial Services Bill (the “Bill”) proposes extending the Senior Managers and Certification Regimes to all regulated financial firms, including insurers, in 2018.
• There may be a double implementation burden for insurers as they will also need to implement the Senior Insurance Managers Regime in 2016.
• The presumption of responsibility in the Senior Managers Regime would be replaced under the Bill with a statutory duty of responsibility.