2025-11-26
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The Abu Dhabi Global Market Financial Services Regulatory Authority proposes regulatory enhancements to align with the IAIS Insurance Core Principles, implement IFRS 17 accounting standards, and establish frameworks for managing climate-related financial risks. The consultation introduces targeted requirements for reinsurance risk management, market conduct, and product development while streamlining miscellaneous operational rules. Additionally, the FSRA outlines initial expectations for all authorized persons to identify, measure, and manage material climate risks within their existing risk and capital adequacy frameworks.
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CONSULTATION PAPER
NO. 13 OF 2025
IAIS INSURANCE CORE PRINCIPLES
AND CLIMATE RISK MANAGEMENT
26 NOVEMBER 2025
Consultation Paper No. 13 of 2025
Table of Contents
Introduction.................................................................................................................... 3
Background .................................................................................................................... 6
A. IAIS Insurance Core Principles ..................................................................................... 7
B. IFRS 17 Insurance Contracts ...................................................................................... 10
C. Miscellaneous Enhancements ................................................................................... 11
D. Climate-Related Financial Risks................................................................................. 12
E. Establishing ADGM as a Hub for Reinsurance .............................................................. 13
Conclusion ................................................................................................................... 14
Appendices................................................................................................................... 15
Consultation Paper No. 13 of 2025
Why we are issuing this paper
Consultation Paper No. 13 of 2025
5. This CP addresses the following topics.
Topic Firms affected
Section A contains proposals to address the
areas where enhancements to the regulatory framework will ensure further, appropriate alignment with International Standards, in this case, the IAIS Principles.
Consultation Paper No. 13 of 2025
8. All comments should be made in writing. When submitting your comments by email,
please use the Consultation Paper number in the subject line. If relevant, please identify the organisation you represent when providing your comments. We reserve the right to publish any comments you provide, including on our website, unless you expressly request otherwise when submitting those comments. Consultation Paper No. 13 of 2025 Abu Dhabi Global Market ADGM Square Al Maryah Island PO Box 111999 Abu Dhabi, UAE Email: fsra.consultation@adgm.com What happens next
9. The deadline for providing comments on these proposals is 30 January 2026. When we
receive your comments, we will consider whether any modifications to the proposed amendments are required. The FSRA will then proceed to enact the proposed amendments in their final form and you should not act on them until the relevant Rules are implemented.
Consultation Paper No. 13 of 2025
Consultation Paper No. 13 of 2025
Impacted Rulebooks and Guidance
6. The proposed amendments will require the amendment of a number of Rulebooks
and Guidance.
Consultation Paper No. 13 of 2025
c. Insurer’s insolvency: we are proposing that an insurer’s risk management system
should consider the risk of insolvency and how its reinsurance contracts will operate in the event of an insolvency of either the ceding insurer or its reinsurer. (PIN 2.3.1 and 2.3.4) d. SPV structures: while PIN 10.1.6 requires that the rights of the providers of any debt or other financing arrangements used to fund an Authorised Insurance Special Purpose Vehicle’s (“Authorised ISPV”) reinsurance liabilities are fully subordinated to the claims of creditors under its contracts of reinsurance, we are proposing explicit amendments to align with the requirement in ICP 13 that investors in an Authorised ISPV may not have recourse to a ceding insurer in the event of an economic loss. e. SPV risk management and internal controls: while PIN 10.1.4 requires an Authorised ISPV to develop, implement and maintain a risk management system to address all material risks to which it is subject, in order to better align with ICP 13, we are proposing to specify aspects that must be considered, including ISPV investment restrictions, collateral management, and asset identification, among other considerations. Question 1: Are there other considerations that should be outlined in the guidance in relation to the selection of reinsurers when an Insurer cedes insurance risk or in relation to the systems for selecting and monitoring reinsurers? Question 2: Are there any other practical aspects in relation to the structuring of Authorised ISPVs which require regulatory consideration? A.2 Market Conduct
9. ICP 19, “Conduct of Business”, requires insurers and intermediaries to, in the
conduct of their insurance business, treat customers fairly, both before a contract is entered into and through to the point at which all obligations under it have been satisfied.
10. While ADGM is currently a largely wholesale-focused insurance market with little
interaction with retail customers, given its ambitions to establish itself as a hub for IAIGs which may have retail businesses, it is appropriate to consider targeted enhancements to our conduct rules for insurance to better align with the standards set out in this ICP.
11. As part of this CP, we are proposing some targeted enhancements, including in areas
where we already have requirements, the key ones being highlighted below.
Consultation Paper No. 13 of 2025 a. Conducting business with licensed persons: we are proposing that an Insurer, Insurance Intermediary or Insurance Manager must only conduct business with entities that are appropriately authorised/registered in their home jurisdiction and should satisfy themselves that such intermediaries possess appropriate levels of professional knowledge and experience. (COBS 7.2.7 and 7.2.8, and Guidance notes 4 to 7) b. Process for developing and distributing insurance products: we are proposing that when designing and developing insurance products, Insurers must take into consideration the following, among other matters:
Consultation Paper No. 13 of 2025
(COBS 7.8.5 to 7.8.7) e. Avoid or properly manage any potential conflicts of interest: while our COBS Rules have extensive requirements in relation to the avoidance or management of potential or crystallised conflicts of interest under COBS 3.5, covering sectors other than insurance, we are proposing that Insurers, Insurance Intermediaries and Insurance Managers must take all appropriate steps to identify, prevent or manage and disclose all conflicts of interest to ensure that its clients are treated fairly and not prejudiced by any such conflicts. Where they are unable to prevent or manage the conflict of interest, the Insurer, Insurance Intermediary or Insurance Manager must decline to act for such clients. (COBS 7.12)
12. Lastly, we are making a number of minor changes throughout COBS 7 to ensure that
appropriate regulatory obligations and expectations are extended to all relevant Authorised Persons, including those playing an intermediation role, in the provision of insurance-related services.
13. We note that while ICP 19 sets out a number of distinct expectations around the fair
treatment of customers, we are considering whether, and if so how, to constructively embed customer fairness into the FSRA’s “Principles for Authorised Persons” (GEN 2.2). However, this is a topic that requires holistic consideration across all sectors of ADGM’s financial services industry. As such, we may set out any expectations for the fair treatment of customers at a future stage. Question 3: Do you agree with the proposed changes to our conduct rules in relation to provision of insurance services? Are there other areas where more guidance is appropriate? Question 4: Do you have any feedback on whether/how the FSRA should embed fair treatment of customers, particularly with a view to the protection of retail customers, in its Principles for Authorised Persons?
14. The International Accounting Standards Board issued IFRS 17 in May 2017,
superseding IFRS 4 Insurance Contracts (“IFRS 4”), and subsequently amended it in June 2020, with it becoming effective for annual reporting periods beginning on or after 1 January 2023. It is intended to provide consistent principles for all aspects of B. IFRS 17 Insurance Contracts
Consultation Paper No. 13 of 2025 accounting for insurance contracts and removes inconsistencies in accounting practices which were previously permitted under IFRS 4.
15. Amendments to the regulatory framework for the insurance sector are proposed to
operationalise IFRS 17 within ADGM. These amendments would primarily be reflected in updates to the PIN and CIB Rulebooks to ensure that accounting for insurance contracts in ADGM is aligned with international best practice. Question 5: Do you have any comments on the proposed amendments to apply IFRS 17 in ADGM?
16. In addition to the legislative amendments proposed above, further miscellaneous
enhancements are being proposed in the following areas to address certain aspects of insurance regulation and improve alignment with broader UAE legal requirements. a. Insurance activity restrictions: clarifying the scope of restrictions applicable to Insurers, Insurance Intermediaries and Insurance Managers, and refining the restriction to act in respect of a contract of insurance to exclude a contract for a risk situated in another Financial Free Zone, outside ADGM. (COBS 7.2.2) b. Client classification: introducing a new provision to streamline the treatment of ceding insurers and insurance brokers as Market Counterparties, thereby eliminating the need for an Authorised Person involved in reinsurance to undertake client classification for that ceding insurer or insurance broker. (COBS 2.5.1 and 2.5.2) Codifying regularly granted relief: repealing the requirement in CIB for Captive Insurers to file quarterly regulatory returns, unless required to do so by the Regulator.
17. Additionally, we are updating the GPM to remove the option for a complainant to
lodge a regulatory complaint via email to the FSRA. This will streamline the process for lodging and effectively dealing with complaints received by the FSRA through the online complaints form located on our website4 . 4 https://www.adgm.com/operating-in-adgm/additional-obligations-of-financial-servicesentities/enforcement/complaints/submit-a-complaint
C. Miscellaneous Enhancements
Consultation Paper No. 13 of 2025
18. These amendments are designed to provide greater clarity, reduce unnecessary
burdens, and ensure that the regulatory framework for insurance in ADGM remains proportionate and effective.
19. International standard setters are increasingly focused on the identification,
measurement, management and disclosure of CRFR as exemplified in various publications from the BCBS 5 and the IAIS 6 . The IAIS has also incorporated consideration of CRFR in the ICPs related to investments and enterprise risk management, specifically in ICP 15, “Investments”, and ICP 16, “Enterprise Risk Management for Solvency Purposes”.
20. In 2023, the FSRA published the UAE Sustainable Finance Working Group’s Principles
for the Effective Management of Climate-related Financial Risks (the “SFWG Principles”) as Guidance 7 . The SFWG Principles are modelled on international standards in this area.
21. In Discussion Paper No. 1 of 2024, the FSRA sought feedback on potential next steps
to encourage or require effective management of CRFR. The response indicated that policy development efforts needed to be undertaken in an iterative, proportionate manner and particular considerations raised included that:
Consultation Paper No. 13 of 2025
22. Against this background, the FSRA intends to set regulatory expectations relating to
the identification, measurement and management of CRFR in an iterative manner over time.
23. As a first step, we are proposing that all Authorised Persons are required to:
a. consider, as part of their systems and controls for managing risks, whether CRFR may be material to their businesses; b. understand and manage their material CRFR in a manner proportionate to the nature of those risks and the nature, scale and complexity of their businesses; (GEN 3.6); and
c. consider the impact of CRFR on their assessment of capital adequacy.
(PRU 10.2, 11.1, A11.1).
24. Notwithstanding the proposed new requirements, our view is that CRFR should be
considered within existing frameworks for risk management, capital adequacy, and disclosure. Accordingly, we have included this expectation as Guidance for Recognised Bodies in MIR.
25. In addition, we are proposing guidance for Authorised Persons on making public
disclosure of material CRFR identified in PRU. Other consequential changes are proposed to CIB, PIN and GLO. Question 7: Do you have any comments on the principles-based, materiality-focused approach to the consideration of CRFR that the FSRA proposes across Authorised Persons and Recognised Bodies? Question 8: In particular, is the Guidance appropriate in relation to:
(i) when CRFR may be considered material; and (ii) the reasonable steps that may be taken to understand and manage material CRFR?
26. As noted earlier in this CP, we anticipate that ADGM will continue to grow and
establish itself as a regional and international hub for reinsurance, with the potential, in time, for IAIGs to be based and regulated here. Given this expectation, it is appropriate for us to consider, holistically and strategically, the topics of E. Establishing ADGM as a Hub for Reinsurance
Consultation Paper No. 13 of 2025 capital/solvency, group supervision, exit and resolution, and public disclosures amongst others with a long-term view to developing this industry sector in ADGM.
27. Having considered international best practices, the FSRA intends to publish a
discussion paper which will provide detail on our preferred direction of travel in relation to a number of areas that are integral to a robust and internationally recognised regulatory framework.
28. The Discussion Paper will invite feedback from stakeholders on a number of topics
that will inform the development of a “best-in-class” regulatory framework that is appropriate to the reinsurance sector in ADGM.
29. The detailed, proposed legislative amendments to the relevant Rulebooks and GPM
are provided in Appendices 1 to 8. We are of the view that these proposed enhancements will support our efforts to ensure ongoing alignment of our regulatory framework with the International Standards and enhance CRFR management by Authorised Persons and Recognised Bodies.
30. We encourage all stakeholders to engage with us by providing written feedback in
relation the topics outlined in this CP.
Conclusion
Consultation Paper No. 13 of 2025
Appendix 1: Proposed amendments to CIB
Appendix 2: Proposed amendments to COBS
Appendix 3: Proposed amendments to GEN
Appendix 4: Proposed amendments to GLO
Appendix 5: Proposed amendments to MIR
Appendix 6: Proposed amendments to PIN
Appendix 7: Proposed amendments to PRU
Appendix 8: Proposed amendments to GPM
Appendices
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Source: Financial Services Regulatory Authority — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works