All member states, including the EEA countries of Norway, Iceland and Liechtenstein, have indicated that they will comply with Recommendation 9. The adoption of Recommendation 9 by European national regulators requires Lloyd’s Europe to make changes to the business that it can accept from brokers and coverholders that are not authorised by a EU/EEA regulator to undertake distribution activities. This will primarily affect brokers and coverholders that have their authorisation in the UK from the Financial Conduct Authority (FCA).
For these brokers and coverholders, from 1 October 2020 Lloyd’s Europe does not accept new business where the risk in question is for a policyholder in the EU/EEA state and where the risk location for that risk is within the EU/EEA.
During March and April Lloyd’s contacted all brokers and coverholders who will no longer be able to bring impacted business to Lloyd’s Europe to explain the changes and the steps that need to be taken.
Lloyd’s Europe is working to ensure that, despite Brexit, Lloyd’s policyholders across the EU/EEA can continue to access the underwriting expertise and financial security of the Lloyd’s market and their existing policies can continue to be serviced by the Lloyd’s market, including the payment of valid insurance claims. Where brokers and coverholders have established EU/EEA authorised companies Lloyd’s Europe has established fast track processes to onboard them.
Note that EIOPA Recommendation 9 does also apply to reinsurance.