On the 25th of April 2025 the Financial Sector Conduct Authority exempted Lloyd’s open market correspondents from section 8(2)(d) of the Short-term Insurance Act, 1998. The section requires an independent intermediary placing non-life insurance business offshore to get the approval of the FSCA which is done under the Offshore Insurance Placement process.
When amendments were introduced into the section in 2018, it was anticipated that Lloyd’s of London acting through open market correspondents would be exempted from the process to place them on equal footing with other intermediaries. However, policies placed with Lloyd’s and Lloyd’s underwriters were excluded from the advantages of section 8(2).
This has been reconsidered and open market correspondents can place business with Lloyd’s underwriters without following the OSIP steps.
There are a number of conditions relating to changing circumstances, governance and oversight, and due diligence requirements in approving open market correspondents. An annual report must be given by Lloyd’s to the FSCA in regard to the value and type of insurance business placed.
FSCA INS Notice 3 of 2025