The Riffle
The ADGM Financial Services Regulatory Authority (FSRA) has released Consultation Paper No. 13 of 2025, proposing wide-ranging enhancements to its insurance regulatory framework. The focus is clear: align ADGM with the IAIS Insurance Core Principles (ICPs), strengthen market conduct rules, mandate IFRS 17, and introduce a cross-sectoral framework for managing Climate-Related Financial Risks (CRFR).
These reforms mark Phase 3 of ADGM’s multi-year programme to embed global standards across all financial sectors.
1. Strengthening Insurance Regulation
The proposals enhance alignment with IAIS standards, particularly around:
Reinsurance & Risk Transfer (ICP 13)
Clearer expectations for reinsurer selection
Stronger claims monitoring
Ensuring firms assess insolvency impacts of reinsurance
Enhanced requirements for ISPVs, covering investment and collateral management
Market Conduct (ICP 19)
Business only with authorised counterparties
Customer-focused product development
Quick action on misleading promotions
Clear disclosure on whether advice is provided
Mandatory identification and management of conflicts of interest
2. Mandatory IFRS 17 for Insurers
All ADGM insurers must adopt IFRS 17 to ensure globally consistent reporting of insurance contracts.
Amendments will apply to PIN and CIB rulebooks.
A new cross-sectoral framework requires all Authorised Persons to:
Assess material climate risks
Manage CRFR proportionately
Consider CRFR in capital adequacy
Guidance also applies to Recognised Bodies and public disclosures.
4. ADGM’s Reinsurance Hub Ambition
ADGM aims to position itself as a regional and international reinsurance hub.
A separate discussion paper will explore capital/solvency, group supervision, resolution planning, and disclosures for IAIGs.
5. Additional Enhancements
Clearer insurance activity restrictions
Simplified client classification for reinsurance
Removal of quarterly returns for Captive Insurers unless required
Online-only complaints process
Impacted Firms
Insurers, intermediaries, captive insurers, all Authorised Persons (for CRFR and complaints), and Recognised Bodies.
Rulebooks impacted include GEN, COBS, GLO, MIR, PIN, CIB, PRU, GPM.
Conclusion
Consultation Paper No. 13 of 2025 marks a major step in modernising ADGM’s insurance regime, aligning it with IAIS principles, embedding climate-risk governance across the market, and paving the way for ADGM’s ambitions as a global reinsurance hub.
The FSRA invites industry feedback by 30 January 2026.
