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“No More Ambiguity” Data Standards and a Vision for a Digitised Market

22nd September 2026

Operations Director

Perspectives from the LMG’s Data Council and Ruschlikon, 24 June 2026.
Compiled and edited by Damien Seaman on behalf of the LMA, the LMG’s Data Council and Ruschlikon.

Introduction

The London market has talked about digitisation for so long that it’s easy to tune out.

What made the LMG’s Data Council full-day event on 24 June 2026 different was its insistence on specifics. Rather than another abstract digital vision, the day was built around the practical machinery that would make a digital market possible: the Ruschlikon best-practice community, the ACORD Global Reinsurance and Large Commercial (GRLC) messaging standards and the Core Data Record (CDR) for

Open Market, Treaty, Delegated Authorities and Claims – as well as pre-bind placing.

The sessions moved logically from vision to evidence to application. The morning asked what good looks like in a data-driven world; the early afternoon showed, screen by screen and message by message, how several major trading partners have actually built it in the Lloyd’s and company market.

The late afternoon turned to the pre-bind world. Here, the CDR promises to bring the same discipline to placing that Ruschlikon has brought to accounting and claims.

Taken together, the sessions suggest a market that has moved past debating whether to standardise and is now working through the harder question of how – and how fast – adoption can spread beyond the pioneers.

Session 1: Vision of a digital London market

The day opened with a scene-setting session led by Joe Brace (LMA), followed by a roundtable discussion with Clarissa Montecillo (ACORD), Matthew Gouldstone (Velonetic) and Stéphane Flaquet (Lloyd’s).

The associations, the standards body, the central services provider and Lloyd’s appearing on one stage signalled that the vision of a digitised London market is no longer the property of any single institution, but a shared programme.

Brace, Operations Director at the Lloyd’s Market Association, began with a clear message. The London market can become faster, more scalable and more automated by adopting shared data standards, particularly ACORD and the Core Data Record. This will support interoperability, digital contracts, automated compliance, faster quoting and more effective use of AI.

Montecillo then came out guns blazing with the urgency behind the vision – why London’s insurance market needs to do this:

“When I first walked into this building 25 years ago, Lloyd’s was the premier insurance market globally. We could afford to take longer than our competitors. Today, that’s no longer the case. Business is moving to other hubs that are faster, cheaper and becoming better in terms of expertise.”
“If we want to stay competitive globally, then we need to make it easier to do business and reduce frictional operational costs.”

Session 2: What does good look like? The Ruschlikon and ACORD story

Troy Hughes (Aon) and Simon Squires (AXA XL), introduced by Kim Darrington (IUA), traced the Ruschlikon initiative from its origins – a small group of like-minded brokers and reinsurers gathering in 2008 at the Swiss Re Centre of Global Dialogue, based in Ruschlikon near Zurich – to today’s expanded community spanning eAccounting, claims and, more recently, ePlacing.

The founding logic remains unchanged today. It’s to reshape the (re)insurance industry, enhance client service and reduce operational cost, as well as digitising the end-to-end process, replacing paper and integrating placing with back-office data through ACORD standard messages.

Hughes and Squires came armed with numbers. Results reported by member firms, presented under the initiative’s own candid banner of “anecdotal evidence that it works”, included:

  • 50% improvement in claims payment turnaround
  • 75% automation rate for technical account statements within a year of implementation
  • 80% reduction in wire transfer and bank fees for AXA XL achieved by Aon’s US operation through net settlement

The striking thing was that the “key wins” for brokers and carriers were essentially the same list:

  • One system
  • No rekeying
  • Fewer bespoke point-to-point builds
  • Faster and better-quality quotes

Standards are a clear and proven way to strip out duplicated cost.

The argument has fundamentally changed since the initiative’s inception in 2008 because the market is already past the point of critical mass with the number of companies that are onboard.

“The number one point is showing everyone: look, this isn’t a pipe dream. This is happening.”

In the early days, making the case meant hacking through uncharted territory. Now brokers and insurers have charted a path for others to follow. It’s particularly significant that leader brokers are taking this seriously.

The result is that after two decades of hard work, the remaining blockers aren’t technical at all. Every market platform in London now has a gateway. With no infrastructural or technological barriers, the connections are there to be made. The main blockers are awareness and acceptance that there’s a problem.

“Everybody wants to talk about AI. But before you get to AI, you need to build a foundation of structured data and data quality. Put the connectivity and data structures in first, it was argued, then let AI superpower them, because AI projects built on paper documents and legacy processing “will get you the wrong answers.”

The payoff for those who do connect is dramatic, with the cost of processing and servicing online business roughly halving.

Session 3: From standards to practice: Swiss Re and Guy Carpenter (Marsh Re)

If the morning made the case for digitisation, the afternoon – after a lunch break for cheese and chat – was about showing the proof in exhaustive detail.

Enrico Alessandri and Lenka Bendova (Swiss Re) with Danny Hickey and Paul Greene (Guy Carpenter), again hosted by Kim Darrington, walked through what is arguably the market’s longest-running ACORD messaging partnership.

Swiss Re and Guy Carpenter (now Marsh Re as of 01 September 2026) began building their solution in late 2007 and went live in 2008. The session walked through it in unusually granular detail, from premium messages and claim movements to two-way queries and financial account settlement.

Danny Hickey was a processing technician at Guy Carpenter when it all started – and that vantage point shapes his central message that this is simpler than it looks. “There’s really no difference in how our technicians process anything,” he told us.

“They don’t need to know how the messaging works. All they do is select the package and click send, and the system takes care of the rest.” In his view, digitisation succeeds precisely when it becomes invisible to the people doing the work. Marsh Re now has more than 40 partners live using full ACORD messaging, “and more wanting to do it every single month.”

Hickey’s larger point is about how that growth happened at all. “We’ve got brokers in competition, insurers in competition, reinsurers in competition – but they’re all seeing the benefits and are all working together for the common good. It’s a community,” he said.

“If companies had been doing this in silos, it wouldn’t have worked. If everyone had gone off and developed their own standards, it would have fallen flat.”

Lenka Bendova, who leads the ePlacing project internally at Swiss Re, gave us the implementer’s view of what makes a connection work: a joint run-through between both teams, so each side understands the other’s systems, requirements and limitations before a single message flows. In Swiss Re’s facultative pipeline, the message bypasses human eyes and goes straight into an automated system, which is one reason why all possible room for error or misinterpretation has to be engineered out up front.

She’s also disarmingly direct about the human anxiety that automation stirs up. “This is tooling,” she tells sceptical end users. “Instead of spending your time dealing with data and dealing with folders, you’re supposed to spend your time reviewing what actually came in. Doing the underwriting job – the intellectual work – instead of the work a machine can do for you.”

“We’re covering people from disastrous losses. If, as an industry, we can put our efforts towards that – instead of keying and rekeying, and having long discussions about the meaning of words in a contract – I think it’s time well spent.”

The lessons-learned slide deserves quoting almost in full, because it captured the market’s maturity on this subject. On the benefits side, the standards are in place; build once, use many times; exchange data and documents automatically in the background; replace manual interactions; realise process efficiencies.

On the considerations side: aligning business processes with the message flow, mapping internal data to the GRLC standard and its codesets, testing both internally and end-to-end, and – perhaps most tellingly – the acknowledgement that end-to-end connectivity means external dependencies, and that the real work is organisational change management and adoption.

Put simply, the technology is the easy part.

Session 4: Pre-bind, the CDR and the Marsh-AXA XL case study

The final session took its cue from Beyoncé and told attendees about the benefit of moving “to the left”. In other words, this session was all about taking the discipline Ruschlikon and ACORD standards have brought to the back office and pushing that into placing, via the Core Data Record.

Kirstin Duffield of Morning Data (a Verisk company), who chairs the CDR working groups and advises the chair of the Data Council, has a knack for making the case vivid.

“A PDF is just a photo of a piece of paper,” she says. “Computers can’t naturally read it, so a human reads it and types the details into their system. When the claim happens, another human copies the same details into their system. Whilst there are AI tools to extract data, they don’t extract it to a multi-dimensional predictable structure without a guidebook – the CDR.”

“What if we stopped trying to send documents and just sent the data? That’s what the Core Data Record does.”

She walked the room through the CDR’s incremental design – data layered in stage by stage, from initial enquiry through submission, quote and bind – and made short work of the objection that Blueprint Two’s sunset makes it irrelevant.

Much of today’s structured placing traffic already runs on the Unified Placing Record; the CDR is designed to build on that, extending it with the Lloyd’s reporting data the market needs once it goes live.

The CDR is the getting-set-up phase, she argued, just as opening a bank account is needed before one-click online shopping becomes possible. The ask is more modest than people fear. “We’re not talking about all the clauses being aligned,” she said. “That’ll come. We’re saying: we’ll call the inception date the inception date.”

Her diagnosis of market resistance is characteristically sharp. People retreat to what they trust (usually Excel). Especially when the pressure is on.

And she’s watched AI hype produce what she calls “gym memberships”: “People have got AI tools, they’re set up, they subscribe, they turn up, they wear the kit, they get it all to proof of concept… and a month later they’re all back on the couch.” The blocker, she concludes, “is a cultural challenge, fuelled by fear and lack of time.”

Marsh x AXA XL case study

The last case study of the day came from AXA XL and Marsh, with Squires returning to the stage alongside Marsh’s Jason Bissessur. They opened with a slide showing two slips side by side: one for the Titanic from 1912, one from 2024. The two documents look almost the same. The way the London market records and trades risk has barely changed in over a century.

The slip itself has gone digital, but the submission – the pack of risk information brokers send underwriters before quoting – still mostly travels by email, and each underwriter rekeys it into their own systems. Converting that into data that flows straight into underwriters’ systems is the change Marsh and AXA XL presented.

The digital future Marsh presented showed the submission captured as structured data and sent by API straight into underwriters’ systems and their pricing tools.

Nobody rekeys anything. Quotes come back faster. And because the data will be in a standard ACORD format, it keeps working after the deal is done, flowing through to accounting and settlement, which is what the case study demonstrated.

When Marsh places a policy with AXA XL, the policy details are captured as structured data during placement. Once the deal is bound, that data flows automatically into the accounting systems, which calculate premium, commission, taxes, insurer shares and settlement amounts. Nobody types anything in again, so there are fewer errors, processing is faster and reconciliation happens automatically.

Marsh got there step by step. First, they moved their brokers from paper slips to digital ones. (The biggest benefit, Bissessur says, was simply breaking the paper habit.) Now they want to capture structured data earlier, before the deal is bound, so it can flow through the whole transaction.

The potential gains are significant. AXA XL estimates that transaction and friction costs currently take up around 45% of premiums. They predict that this way of working could change an underwriter’s job from 80% manual work to 80% strategy.

Before the advent of the trading platforms, an underwriter received thousands of broker emails a year, with heavy endorsement traffic flowing through their inboxes. Because of this, underwriters used to say they lost up to 30% of their time on administration. But, as the session showed, if you connect via standards and APIs, your underwriters don’t need to get involved in any admin. For the first time ever, carriers could give their underwriting teams 30% of their time back – particularly significant given that underwriters tend to cost firms three to four times more than operational staff.

There’s also a competitive reason not to wait: the rise of digital follow. Brokers are building standardised digital facilities, and algorithmic followers like Ki can quote from structured data in hours.

“If you’re a traditional follower still using unstructured data and old-fashioned processes, and you can’t come back with a quote in under 24 hours, you’re going to lose out.”

Over the last ten years, operating costs have gone up by 30%. Far from getting cheaper, the market has just got more expensive. For the first time ever, if the market moves to data standards and direct connectivity, it could turn the dial back. Tim Pledger of Swiss Re, founder of the Ruschlikon Blueprint Two group, adds that Ruschlikon participants have already turned that dial back: “If the London market doesn’t catch up and reduce operating costs using standardisation and associated automation, business may be lost to other territories,” he says.

What next?

Perhaps the most encouraging shift has been taking place behind the scenes: the largest brokers have started adopting the standards. Tim Pledger points out that Aon, Marsh, Guy Carpenter (Marsh Re) and Willis are now all engaged with ACORD messaging across insurance and reinsurance.

That kills a long-standing excuse. Carriers have traditionally said they’d go digital as soon as brokers supplied the data. “Well, the brokers are willing to supply it,” Pledger says. “We’ve now got to be able to use it.”

Pledger is candid that the market has made trade-offs along the way. The original CDR vision was a central record that services could interrogate to automate processing; the incremental CDR, he notes, delivers bilateral data exchange through the placement cycle. This is hugely valuable, but not yet that central engine.

His response, though, is a to-do list rather than a lament: use the market’s structured data capture service so “everyone’s got the same data right up front.” Encourage a long-term plan from central services that embraces ACORD messaging and, eventually, a hosted contract record to automate processing end to end. Fifteen years of Ruschlikon eAccounting shows what that patient, standards-first route can deliver: “We’re just starting that journey on ePlacing.”

Which brings the day full circle. The standards exist. The gateways are live. The case studies are public, shared freely by competitors, and the C-suite is finally asking about them unprompted.

What remains is the very human work of adoption: the mindset shifts, the management commitment, the willingness to change a process you’ve trusted for twenty years.

“Unless you’re in amongst all the operational toil, you probably don’t understand how transformational this can be.”

Conclusion and key takeaways

Across the day, several threads kept resurfacing.

  1. The standards argument has been won, and there’s plenty of evidence that it works. The Ruschlikon community’s metrics – however anecdotal – and the 18-year Swiss Re-Guy Carpenter partnership demonstrate that GRLC messaging works at scale, across premium, claims, queries and settlement. It pays for itself in cash flow, data quality and eliminated rework.

    As Joe Brace put it in his end-of-day wrap-up: “It’s a hell of a lot easier to see what someone else has done than to do it from scratch.” The tools and the case studies are there. That’s the point of the community the day showcased: learning from each other, making common cause, hearing how we solved the problem rather than facing it alone.

  2. Adoption, not technology, is the constraint. The most repeated cautions concerned business process change, mapping, testing, external dependencies and organisational change management. The most successful implementations were those in which the standard became invisible to practitioners.

  3. Convergence between the post-bind and pre-bind worlds. Ruschlikon started at the back office and is working forward. The CDR, once live, will start at placing and work backward. Both meet in the same vision of one interconnected digital transaction, linked end to end, with no departmental silos and a single view of the truth shared by client, broker and carrier, with every ambiguity taken out. And that vision runs right through to settlement. “We don’t want to move the wrong money to the wrong place,” Brace reminded the room. “Money is only data. Think about the processes, the data and the controls that are in there.”

  4. AI won’t fix the London market, only industrialise its inconsistencies. Feed it PDFs, rekeyed data and broken processes and you just get wrong answers delivered faster, at scale and with more confidence. Every speaker who touched the subject said the same thing, and the market should hear it as an instruction. The unglamorous standards work everyone keeps deferring isn’t the alternative to an AI strategy. It’s the price of having one.

“AI is built on data, that’s the foundational layer that sits underneath it,” said Brace. And, he stressed, “none of this takes the human out of it.” The day-to-day oversight, the analysis and the controls remain human work: automated processing, but with reports and human control wrapped around it.

Brace closed with a carrot and a stick. The stick: nobody wants to be left behind.

“If you do the things we’ve talked about today, you’re preparing for that future world. If you haven’t, you’ll be standing still while everyone else is jogging and warmed up. You can see the direction this is going.”

The carrot was an appeal to ambition beyond cost: “Cost is a thing. But we’ve got to lift our eyes higher” towards the underwriting and risk gap, and the time everyone could free up for conversations about new products.

His parting advice was practical. “Don’t try to boil the ocean.” Eighty percent of the market’s premium comes through the top 10 brokers, so start with your biggest client, have a chat and be intentional about what you’re trying to achieve. And talk to your associations.

If this event was a barometer, it suggested a market that knows what good looks like, can point to partners who have built it, and now faces the less glamorous but more consequential task of making it everyone’s normal way of trading.

Quotes in this report are drawn from the event sessions and from follow-up interviews conducted with speakers and market participants in July 2026. With thanks to all interviewees.

Resources

Replay – US Jurisdiction: Picking Your US Battleground

18th September 2026

The LMA recently hosted the second in our series of talks on law and jurisdiction: Picking Your US Battleground. This practical session explored how insurers can control where their disputes get decided and the merits or otherwise of US arbitration.

The event was opened by Arabella Ramage, Legal and Regulatory Director at the LMA, and led by Chris Paparella, Partner at Steptoe.

Replay – Financial Institutions Cyber Clauses Briefing

17th September 2026

The LMA Financial Institutions Committee’s Cyber Clauses Briefing explored how financial institutions professional indemnity and cyber policies may respond when a financial institution suffers a cyber attack.

The session focused on the LMA’s model FI professional indemnity cyber clauses, including the recently updated LMA5478B, with speakers reviewing relevant coverage and exclusions and discussing key issues at the intersection of professional indemnity and cyber exposures.

The briefing provided attendees with a clearer understanding of how FI and cyber policies may respond to a cyber act against a financial institution and the considerations for underwriters, legal and wordings professionals when assessing these exposures.

Speakers

  • Caroline Smith, Head of Financial Institutions, Newline, and Chair of the LMA Financial Institutions Committee
  • Jenny Boldon, Partner, Kennedys
  • David Powell, Head of Technical Underwriting, LMA
  • Toby Clark, Executive, Technical Underwriting, LMA

The webinar recording and presentation slides are available below.

Updated ACOD Clauses Published

14th September 2026

The LMA’s International Casualty Business Reinsurance Panel has published the following Accident Circle Occupational Disease (ACOD) clauses:

  • LMA5711 ACOD/B (Amended) EL/Worker’s Compensation – Communicable Disease Variant
  • LMA5712 ACOD/C EL/Worker’s Compensation – Communicable Disease Variant

The panel identified as part of Project Spring Clean that two of the existing ACOD clauses, LSW1602 and LSW1603, needed updating to include communicable disease as part of occupational disease, to align with the IUA version. The new clauses, LMA5711 and LMA5712, have been published as a result of this work. LSW1602 and LSW1603 remain active as requested by the panel.

All LMA model clauses are purely illustrative and are published and distributed for the guidance of Lloyd’s managing agents, brokers and other market participants. All contracting parties are free to agree to different conditions/amend the model clauses as they see fit; the LMA does not protect its intellectual property rights over model clauses. It is for underwriters to decide whether or not any contractual language is acceptable on any given risk. Model documents are available on the Lloyd’s Wordings Repository (LWR).

Claudia Goodridge
Senior Executive, Technical Underwriting
claudia.goodridge@lmalloyds.com 

Jay Desai
Executive, Legal Trainee
jay.desai@lmalloyds.com

Updated TRIA Endorsement Published

10th September 2026

The LMA’s Wordings Committee has updated LMA5341 (TRIA 2020 Endorsement) to address the situation should the Terrorism Risk Insurance Program not be reauthorised before its expiry on 31 December 2027. The new clause will be published as LMA5341A (TRIA 2027 Endorsement). LMA5431 will be archived on the Lloyd’s Wordings Repository (LWR).

If the Terrorism Risk Insurance Program is reauthorised, the policyholder disclosure notices listed below will be reviewed against any updated NAIC model disclosures and revised as necessary.

  • LMA9185A
  • LMA9156A
  • LMA9183A
  • LMA9184A

All LMA model clauses are purely illustrative and are published and distributed for the guidance of Lloyd’s managing agents, brokers and other market participants. All contracting parties are free to agree to different conditions/amend the model clauses as they see fit; the LMA does not protect its intellectual property rights over model clauses. It is for underwriters to decide whether or not any contractual language is acceptable on any given risk. Model documents are available on the Lloyd’s Wordings Repository (LWR).

Ray Koh
Legal Counsel
ray.koh@lmalloyds.com

Jay Desai
Executive, Legal Trainee
jay.desai@lmalloyds.com

MS Amlin’s Christiern Dart joins LMA Board

London, 10 September 2026: The Lloyd’s Market Association (LMA) today announces the appointment of Christiern Dart, Chief Executive Officer of MS Amlin, to the LMA Board. The LMA is governed by a Board that sets the overall strategy, direction and priorities of the Association. The Board is made up of senior market practitioners and LMA leaders.

Clare Constable, Chief Claims Officer of MS Amlin, has stepped down from the LMA Board.

Sheila Cameron, Chief Executive Officer of the LMA, commented: “We are delighted to welcome Christiern to the Board. With more than three decades of leadership experience across the international (re)insurance market, Christiern brings deep insight from across the Lloyd’s market and a strong understanding of the opportunities and challenges facing managing agents. We look forward to working with him as we continue to advocate for our members and make the market a better place.

“I would like to thank Clare for her contribution to the LMA during her time on the Board.”

ENDS

Notes to Editors

Media relations contacts

LMA:
Carole Porter, Head of Marketing and Communications | +44 20 3307 3947 | Email: carole.porter@lmalloyds.com

Omnia Partners:
Victoria Sisson, Director | +44 794 129 4872 | Email: victoria.sisson@weareomniapartners.com

Notes

About the Lloyd’s Market Association

The Lloyd’s Market Association (LMA) exists at the very heart of Lloyd’s, a world-leading global marketplace for complex risk where solutions to challenges are delivered every day. 59 Lloyd’s managing agents and members’ agents are members of the LMA.

We represent our members’ interests to organisations including governments, regulators, and the market’s central supporting body, the Corporation of Lloyd’s. We provide professional and technical expertise in areas ranging from model policy wordings to the implementation of innovative technologies. We connect with our members to identify and resolve issues facing the market, and work in partnership with Lloyd’s and the other market associations to influence initiatives and outcomes. We operate the market’s most comprehensive technical education service, the LMA Academy. For more information visit: www.lmalloyds.com.

Binding Authority Complaints Endorsements: 2027 Updates

8th September 2026

Lloyd’s has updated the suite of complaints endorsements that apply to Binding Authority Agreements to reflect changes to FCA reporting requirements and, for certain territories, the expected move from a two-stage to a one-stage complaints process.

The changes vary by territory and will affect Binding Authority Agreements incepting or renewing from 01 January 2027. Managing agents should review the updated requirements and relevant endorsements when preparing upcoming renewals.

The bulletin below provides further detail on the changes for the UK, Singapore, Hong Kong, international business, Australia, New Zealand and Canada, together with a full table of the new and updated endorsements.

Attachment: Binding Authority Complaints Endorsements Bulletin

Contact

Diane Gillett
Senior Executive, Delegated Authority
diane.gillett@lmalloyds.com

Claudia Goodridge
Senior Executive, Technical Underwriting
claudia.goodridge@lmalloyds.com 

Casualty Clash Excess of Loss Reinsurance Agreement Language Published

26th August 2026

The LMA’s North American Casualty Reinsurance Business Panel has published LMA5710 Casualty Clash Excess of Loss Reinsurance Agreement.

LMA5710 is not intended to be used as a standalone clause. Instead, it contains model language that may be incorporated into and adapted for the relevant Casualty Excess of Loss Reinsurance Agreement. Underwriters will need to ensure that the wording operates coherently within the overall contract, including ensuring that the definition of policy aligns with that used in the existing contract.

All LMA model clauses are purely illustrative and are published and distributed for the guidance of Lloyd’s managing agents, brokers and other market participants. All contracting parties are free to agree to different conditions/amend the model clauses as they see fit; the LMA does not protect its intellectual property rights over model clauses. It is for underwriters to decide whether or not any contractual language is acceptable on any given risk. Model documents are available on the Lloyd’s Wordings Repository (LWR).

Contact

Claudia Goodridge
Senior Executive, Technical Underwriting
claudia.goodridge@lmalloyds.com

Cyber and Financial Lines Claims Podcast: Exploring the Intersection of Cyber and D&O

13th August 2026

Cyber incidents are becoming increasingly complex, with potential consequences extending far beyond the immediate technical and financial impact. As businesses face growing regulatory scrutiny, shareholder expectations and litigation risks, the lines between Cyber and Directors’ & Officers’ (D&O) insurance can increasingly overlap.

In this episode of LMA Talks, members of the LMA’s Financial Lines Claims Group and Cyber Claims Group come together to explore the evolving relationship between Cyber and D&O claims.

The panel considers how cyber incidents can trigger D&O exposures, the challenges that can arise when policies overlap and the key legal and regulatory developments shaping the claims landscape.

They also share insights into what claims professionals should be considering as cyber risks continue to evolve and financial lines claims become increasingly complex.

Featuring:

  • Michael Ehioze-Ediae, Co-Chair, LMA Financial Lines Claims Group & Senior D&O and FI Claims Underwriter, Hiscox
  • Carolyn Thomas, Chair, LMA Cyber Claims Group & Head of Cyber and Financial Lines Claims, Munich Re Specialty Group
  • Amit Tyagi, Partner, CMS
  • Carly Marston, Head of FinPro Claims, Liberty Specialty Markets

Listen to the podcast below.

Legal and Regulatory Update, August 2026

3rd August 2026

The first half of 2026 was a very busy and productive time for the LMA’s Legal and Regulatory team. We’ve engaged on a diverse range of topics across the market while continuing to support our colleagues in Underwriting, Claims, Operations, Finance and Risk and the LMA Academy.

Below, we’ve outlined the key successes and activities the team has worked on and delivered. While not exhaustive, this summary offers a snapshot of the impactful work supported in H1.

For further updates on our ongoing consultations and focus areas, access our monthly Legal & Regulatory Radar.

Geopolitical work

The Legal and Regulatory Team’s geopolitical work has been dominated by Iran, including:

Shipping: Following the outbreak of the Iran conflict, we dealt with various issues arising out of notices of cancellation across marine classes and worked to correct press and political misinterpretation that these represented a withdrawal of war cover. We addressed member, regulatory and press questions on reinstatement, Strait of Hormuz transits, consequential delay, grip of the peril, the DFC scheme and payments for transiting territorial waters. The Joint War Committee amended restricted areas, including US military bases, and we spoke at a London Risk Week event alongside Antares. The Legal Committee also heard from Richard Waller KC on potential legal issues arising out of the closure of the Strait.

International waters and shadow fleet: We considered the risk implications of US/UK appetite to board foreign-flagged vessels in international waters and options for scrapping unusable ‘shadow fleet’ vessels involved in Russian oil shipping, including through RUSI and other discussions.

Aviation: At the Aviation Hull War Committee’s request, the LMA issued LMA5703 stating that underwriters could reasonably treat the resumption of Middle East operations after airspace closures as a material change of risk under LSW555D. LIIBA’s Aviation Committee has challenged this position. The LMA also reminded leaders of duties to inform followers of contractual changes and obtained legal advice from the top 10 aviation jurisdictions on automatic termination.

Sanctions: We received advice from Richard Neylon and John Kimbell KC on sanctions and terrorism issues linked to toll payments for Strait transits and they presented a webinar on the subject to the market. The LMA continues to work with Lloyd’s on sanctions and licensing changes, aiming to minimise divergence between US, UK and EU regimes. Key issues include changes to the Russian oil price cap, US sanctions on Iranian oil and Venezuela sanctions, and the practical implications of an increasingly fragmented sanctions landscape.

Tolls: We assessed the insurance implications of toll payments for Strait transits and engaged extensively with OFAC and OFSI on their interpretation. Following the sanctions event (above), we worked with Jawdat Kurshid KC to produce a clause supplementing the sanctions clause and discharging cover upon a toll payment being made. The clause and guidance were shared with OFAC and OFSI, and following consultation with insurers, brokers and regulators has been published.

War clause/five powers project: A CUO committee-led working group is considering how to improve certainty around the use of ‘five powers’ war clauses, where cover terminates on war between any two powers. The actual moment of termination is difficult to define when the ‘war’ is not ‘boots on the ground’. The work is expected to proceed in two phases:

  • agreeing a clause wording and examples of what will, and will not, constitute war between the five powers, and assessing use of a suspensory mechanism rather than automatic termination;
  • reviewing whether a more flexible mechanism, potentially involving an independent expert panel, could reduce disputes. Discussions continue with the market, LMG, reinsurers and brokers.

Other geopolitical work

Engagement has covered government backstops for war and NatCat exposures, insurance affordability and cyber insurance penetration in the SME market. On NatCat, we met EU Commission representatives to discuss options for closing protection gaps in Europe.

International engagement

Insurance Europe and Global Federation of Insurance Associations (GFIA) conferences: Arabella Ramage and John Levett attended the Insurance Europe annual conference and GFIA Spring General Assembly in Brussels in May, engaging with other national trade bodies 1:1 on geopolitical risk and local market issues.

RIMS: Arabella Ramage, with Gavin Williams from Starr, presented The Questions you did not Know to Ask: Insurance Across Jurisdictions, covering hazards and pitfalls in international placements.

Legal

Legal Committee: Katy Wilson of Ascot succeeded Rhic Webb of Aegis as chair, with Matthew Hunter of Asta and Alexandra Smith of QBE joining as new members. The committee has considered AI governance and lessons from Russian aviation litigation in the context of the Middle East conflict.

LIC Managing Agency Outsourcing Agreement: The Legal Committee considered LIC-requested amendments, many from the NBB. The final agreement will be distributed to the market in August.

Enhanced underwriting: We published ‘Navigating the risks of enhanced underwriting’ in the International Comparative Legal Guides (ICLG) to Insurance & Reinsurance 2026, covering additional risks in enhanced underwriting models. The chapter is available on the LMA website.

Product liability legislation: The Legal and Claims Committees had input into the LMA’s representations in relation to questions asked by the Law Commission on the potential reform of product liability legislation in the UK and in particular the incorporation of information technology/AI into products. 

EU Retail Investment Strategy (RIS) watching brief: Proposed RIS amendments to the EU Intermediation Directive that could have affected third-country broker and carrier branches were deleted, but related work is expected in the IDD review from 2027. The Legal and Regulatory Committees will maintain a watching brief.

Trainees: Jay Desai joined the Legal Wordings Trainee Scheme and Dorottya Tornai qualified into QBE’s legal department. Current secondments are:

  • Max Gross – Convex
  • Muhammad Hammad – Munich Re Syndicate
  • Daniella Olu-Davies – Aegis

Emerging Litigation Forum

  • Shoosmiths presented key litigation trends for 2026, including AI implementation risks. A summary is available here.
  • Clyde & Co presented on recent litigation concerning social media addiction. A replay is available here.

Lawyers’ Forum: Kyle Moran and Alan Harrell of Phelps Dunbar presented on PFAS, toxic torts and public nuisance claims. Bob Haken and Will Reddie also presented on operational resilience following recent PRA policy statements.

Law and jurisdiction event: Harry Wright of 7KBW, Rani Noakes of 4 Pump Court and Katie Wilson of Ascot presented on the importance of law and jurisdiction in policies, available here. A US-focused follow-up is provisionally planned for 15 September.

FERN 3: Work has commenced in earnest on the review of FERN 3 aka the CPSA. We have engaged Clifford Chance in conjunction with the IUA to conduct a review of the draft contract.

Regulatory Committee

New members: Natasha Grasso (Berkley), Kevin Ball (Asta) and Natalie Dick (Riverstone) joined the committee in March, bringing new market perspectives.

International Forum: Simon French (Travelers) has taken over as chair for these sessions. Invites are now sent out as LMA bulletins so please sign up to attend these useful updates through the events page of the website.

Insurance Europe: The LMA has formally joined Insurance Europe, supporting our regulatory strategy and international influence. We are attending committees and reporting significant consultations through the Regulatory Radar.

Simplifying insurance rules: Following the FCA’s December 2025 policy statement, the LMA worked with members on market guidance, now published. We continue to lobby on the consumer definition and extra-territorial application of Consumer Duty, with further consultation expected in Q3.

PRA DyGIST: We supported risk colleagues on the PRA dynamic stress test, including Lloyd’s Market Day in February, and fed market reactions back to Lloyd’s and the PRA.

Non-Financial Misconduct: Following the FCA’s publication of updated guidance in December, the LMA coordinated with the IUA and LIIBA on a new webinar update to the market. This is available to rewatch here. We have also responded to the UK government consultation on use of non-disclosure agreements in employment disputes.

Operational Resilience: incident and material third-party reporting: March policy statements addressed several LMA concerns, but breadth and implementation remain issues. A working group is collecting views on proportionality and implementation costs.

Modernising redress and the Ombudsman Service: This work continues with more consultations released in Q1 alongside a policy statement. We are working with members of the RegCom and Conduct Committee on what work is needed in the application of these changes. 

Lloyd’s Two Stage Complaints Process: The LMA supports moving from blanket Lloyd’s oversight to an outcomes-based approach focused on managing agent performance. Consultation ended in March, with implementation expected early next year.

Senior Managers and Certification Regime (SMCR): Phase 1 has gone live and phase 2 is expected for consultation later this year. The LMA is updating guidance and has circulated the FCA survey so managing agents can identify burdensome parts of the regime and support lobbying.

Saudi Arabia foreign reinsurer registration: The LMA worked with Lloyd’s international regulatory team to keep the market informed and requested an extension to the registration deadline. The deadline moved to the end of May and all managing agents are now registered. More information is available in Crystal+.

Financial Services Bill: We worked with the LMG and Lloyd’s on proposed changes to the draft bill to allow the PRA and FCA to rely on Lloyd’s for work such as on senior manager authorisation.

Other matters

Brazil: The LMA continues to work with local counsel on Brazilian regulatory changes. An amended Duty of Enquiry endorsement has been published, further endorsements are in development and we are working with Lloyd’s and the Brazilian insurance association on clause awareness and feedback.

India: Lloyd’s GIFT City platform in India went live in 2026 and the Lloyd’s multinational team also signed an agreement with a local fronting partner for use by the market on multi-national placements.

India have also begun the implementation of their mandatory Reinsurance placement platform ETASS Re.

The LMA is facilitating information sharing on these developments via our International Forum. Further information is available on Crystal +.

Cyber: We have created a simple modular SME product and are considering how cyber insurance can support key suppliers affected by cyber events. The SME product is being finalised.

Consultations: The LMA has reviewed and triaged 105 consultations and responded to 20, including The Mills Review into the long-term impact of AI on retail financial services:

  • The European Commission Fighting online fraud – action plan
  • The European Ocean Act
  • CP25/37: Targeted clarifications of Handbook materials – FCA
  • CP25/35: Quarterly consultation paper No.50
  • European Commission: Climate Resilience Framework Consultation 2026
  • CP25/33: Regulatory fees and levies: policy proposals for 2026/27 –  FCA
  • Product liability – law commission
  • EU public procurement rules – revision
  • Consultation on the Appointed Representative regime
  • Ownership and Control Test in UK Financial Sanctions Regulation
  • Complaints Handling at Lloyd’s
  • Economic Crime Information Sharing
  • CP 26/9: Modernising the Redress System
  • Trade in a Turbulent World: How Should the UK Deploy Its Trade Instruments?
  • HM Treasury Market Engagement Group
  • Call for Evidence: Committee Inquiry – EU
  • Call for Evidence: Committee Inquiry – US
  • Targeted Consultation on the Competitiveness of the EU Banking Sector
  • Microsoft Business Software and IT Services Market Investigation

The latest responses can be found on our website.

Arabella Ramage
Legal and Regulatory Director
Lloyd’s Market Association

Issued: 03 August 2026