Insurance Executive Hiring Guide UK

Insurance is not one market. A Lloyd’s managing agent, a UK-authorised carrier, a managing general agent and a broker operate under different regulatory regimes, make money in different ways and draw on largely separate candidate pools. Boards that treat “insurance experience” as a single qualification tend to appoint someone whose background does not match the business they have joined, and in a regulated sector that mismatch is expensive to unwind.

This guide sets out those distinctions, the regulatory framework that governs senior appointments at insurers and intermediaries, the senior manager functions that exist only in insurance, the changes to the Senior Managers and Certification Regime now in progress, and how to assess candidates in a market where technical judgement is hard for non-specialists to test. It is written for boards, chairs, nomination committees and investors planning a senior hire, and it reflects how our insurance recruitment team approaches these mandates.

Four different businesses

Before writing a brief, be clear which of the four business models you are hiring into. The commercial engine, the regulatory perimeter and the executive agenda differ in each.

Carriers

Insurers hold the risk and the capital. They are dual-regulated: the Prudential Regulation Authority supervises safety and soundness, and the FCA supervises conduct. Reserving, capital management, investment strategy and reinsurance purchasing dominate the executive agenda, and the board spends a great deal of its time on matters that depend on actuarial judgement.

The Lloyd’s market

Managing agents run syndicates within the Lloyd’s market. According to Lloyd’s own summary of how the market is regulated, Lloyd’s is regulated by both the FCA and the PRA, managing agents are dual-regulated, and members’ agents and Lloyd’s brokers are regulated by the FCA alone. On top of that sits the Corporation of Lloyd’s, with its own byelaws, business planning process and performance oversight. Executives who have worked inside that structure understand the syndicate business plan cycle, capital setting and the relationship with the Corporation in a way outsiders take time to learn. For specialist underwriting appointments, see our Lloyd’s of London underwriter search.

Managing general agents

MGAs underwrite on delegated authority using another insurer’s capacity. They do not carry the balance-sheet risk, and as insurance intermediaries they are solo-regulated by the FCA rather than dual-regulated. Capacity relationships are the strategic asset: an MGA whose capacity provider walks away has no product to sell. The leadership agenda is about underwriting performance that keeps capacity in place, data and pricing capability, distribution, and operational control of a delegated model.

Brokers

Brokers are distribution businesses. They are FCA-regulated, capital-light, and much of the UK broking sector has been reshaped by acquisitive groups and private equity ownership. The executive agenda centres on client retention, integration of acquired books, Consumer Duty, client money and the finance discipline that buy-and-build strategies require.

The commercial models differ fundamentally. A carrier makes money on underwriting result and investment return. An MGA earns commission and profit share without carrying reserve risk. A broker earns on distribution. An executive moving from one to another needs genuine time to become useful, so the brief should state which experience is essential and which would simply be helpful.

The regulatory framework for senior appointments

Insurance sits under a heavier and more specific regime than most of financial services, and it directly affects hiring timetables.

Dual regulation at carriers. Insurers and Lloyd’s managing agents answer to two regulators. Some senior manager functions are prescribed by the PRA and some by the FCA, and the application is assessed with both in mind. Brokers and MGAs deal with the FCA only, which generally makes approval simpler.

The Senior Managers and Certification Regime. The SM&CR applies to insurers and to solo-regulated intermediaries. Designated senior manager functions require regulatory approval, and each holder needs a Statement of Responsibilities setting out what they are accountable for. Solo-regulated brokers and MGAs fall into the core or limited scope tiers depending on their permissions, with the largest firms classed as enhanced; dual-regulated insurers follow the PRA’s insurance version of the regime.

Key function holders. Beyond the senior managers, the prudential regime for insurers requires firms to have effective risk management, compliance, internal audit and actuarial functions, and to make sure those who run or perform key functions are fit and proper. In the UK this framework has been rebuilt as PRA rules: the PRA’s final Solvency II reform package took effect on 31 December 2024, when the retained EU law was revoked and replaced by the PRA Rulebook. The reformed regime is commonly called Solvency UK, although the PRA has said it will continue to use the Solvency II name for now. Key function holder appointments are frequently overlooked in hiring plans until a supervisor raises them.

Regulatory references. When appointing a senior manager, firms must request regulatory references from previous regulated employers covering the past six years, in a prescribed form. This lengthens the period between offer and start, and occasionally surfaces matters that change the appointment.

Approval before performance. A candidate cannot perform a pre-approved senior manager function until approval is granted, other than under the temporary cover rules for unforeseen absences. The regulators have a statutory period of up to three months to determine a complete application. The practical consequence is simple: build approval into the offer, plan the start date around it, and never announce an appointment as effective before approval is confirmed.

The senior manager functions specific to insurance

Most of the senior manager functions at an insurer will be familiar from banking: Chief Executive (SMF1), Chief Finance (SMF2), Chief Risk (SMF4), Head of Internal Audit (SMF5), Chair (SMF9), committee chairs and the Senior Independent Director, plus the FCA’s Compliance Oversight (SMF16) and Money Laundering Reporting (SMF17) functions. Three PRA functions exist only in insurance, and they are where specialist search matters most.

• SMF20 Chief Actuary. The individual responsible for the actuarial function, including the reliability of technical provisions. With-profits life business also requires a With-Profits Actuary (SMF20a).
• SMF23 Chief Underwriting Officer. Responsible for the firm’s underwriting, including underwriting strategy, risk appetite and the performance of the book. This is the function held at carriers and Lloyd’s managing agents. Our SMF23 Chief Underwriting Officer recruitment page covers how we run those searches.
• SMF23a Underwriting Risk Oversight (Lloyd’s). A different function, often confused with the CUO. The PRA Rulebook defines it as overseeing and influencing the underwriting plans of managing agents, and it applies only to the Society of Lloyd’s itself. It is not the Chief Underwriting Officer role at a syndicate.

Our guide to SMF20 and SMF23 explains both functions in more depth. Overseas insurers writing UK business through a branch also need a Head of Third Country Branch (SMF19), a pre-approved role that combines local accountability with reporting to a parent abroad; see our SMF19 recruitment page.

For brokers and MGAs the list is shorter. A limited scope firm typically needs an approved individual in the limited scope function (SMF29); a core firm will usually have a Chief Executive, an executive director or partner functions, Compliance Oversight and an MLRO. Many smaller intermediaries struggle to find a credible head of compliance who understands both conduct rules and the realities of a delegated authority model.

What is changing in SM&CR

The regime is being reformed in two phases, and anyone planning insurance appointments over the next year should follow both.

Phase 1 (in force from April 2026). The FCA and PRA made a first set of changes in April 2026. They were largely administrative: longer deadlines for updating Statements of Responsibilities and the Directory, criminal record checks valid for six months rather than three, and an expectation that firms answer regulatory reference requests more quickly.

Phase 2 (proposed, not yet in force). In October 2026 the PRA published CP14/26 and the FCA published CP26/37. The proposals would remove the Certification Regime and move a number of senior manager functions from pre-approval to notification. In the PRA’s proposals, SMF20 Chief Actuary and SMF20a With-Profits Actuary would move to notification, while SMF23 Chief Underwriting Officer and SMF23a remain subject to pre-approval, as do the Chief Executive, Chief Finance and Chief Risk functions. The temporary cover period would extend from 12 to 18 weeks. The consultations close in January 2027, and the changes depend on new primary legislation, so implementation is not expected before the second half of 2027.

For now, plan every insurance appointment on the current rules. Notification, when it arrives, will shorten some timetables but will not reduce the board’s duty to satisfy itself that the appointee is fit and proper, and the regulators have said they will keep powers to require approval where they have concerns.

Where the candidates come from

Underwriting. The traditional route to leadership at carriers and syndicates. Underwriters are strong on risk selection, pricing and market relationships. The gap is often operational and financial breadth, and the best underwriters do not always want general management.

Actuarial. Increasingly common in chief executive and finance roles at carriers. Actuaries bring depth on reserving, capital and pricing. Test commercial instinct and stakeholder skill; technical depth is rarely the constraint.

Broking and distribution. Client-facing leaders with strong commercial and relationship capability. A natural fit for brokers and MGAs, and a bigger step into a carrier where reserving and capital dominate.

Claims and operations. An underused pool. Claims leaders understand where underwriting assumptions failed, which is valuable intelligence, and they often run larger teams than underwriters do.

Finance. Insurance finance is specialised. Reserving, reinsurance accounting, the Solvency II balance sheet and IFRS 17 make an insurance CFO a different hire from a CFO in other sectors. Candidates from audit firms’ insurance practices are a useful source for second-line and finance roles.

Wider financial services. Banking and asset management candidates bring regulatory familiarity and capital literacy. The insurance-specific gap is real: reserving judgement, reinsurance structure and the workings of the Lloyd’s market. Assess it rather than assume it away.

The Chartered Insurance Institute qualifications are the recognised professional credential in underwriting, broking and claims, and Chartered status carries weight with boards. In actuarial roles the equivalent is fellowship of the Institute and Faculty of Actuaries.

Assessment: what to test

Interviews for insurance leadership roles often stay at the level of strategy and culture because the panel is not confident probing the technical substance. These four questions work across most senior roles and are hard to answer well without real experience.

“Talk me through a reserving decision you were involved in where the answer was contested.” The most revealing question for carrier appointments. It tests technical grasp, comfort with judgement under uncertainty, and how the candidate handles disagreement with the actuarial function or the auditors. Insurance is the sector where the accounts depend most heavily on judgement, and a chief executive who cannot interrogate the reserving position depends entirely on the people producing it.

“Describe a class of business you exited. What did it cost and how long did the run-off take?” Underwriting discipline means being willing to stop. Candidates who describe only growth have either been lucky with their timing or were not the ones making the decisions.

“How did you manage your capacity providers or reinsurers through a difficult year?” Essential for MGAs, where capacity is the business, and revealing at carriers on reinsurance strategy. Look for candour about a year that went badly.

“What did your regulator raise with you most recently, and how did you respond?” Every senior insurance executive has regulatory interaction. A candidate who presents an entirely untroubled history warrants careful reference work, and the regulatory references will cover the past six years in any case.

For non-executive appointments, the questions shift towards challenge: how the candidate tested management’s reserving assumptions, what they asked of the risk function, and how they handled a disagreement with the executive. The regulators look closely at whether an insurance board has enough technical knowledge between its members to hold management to account.

Timeline, notice periods and reward

Allow considerably longer for a pre-approved function at a dual-regulated carrier than for an FCA-only broker or MGA. Most of the extra time sits in regulatory approval and reference gathering rather than in the search itself, and the statutory three-month determination period gives a sense of the outer limit once an application is complete. Incomplete applications, unanswered regulator questions and late references are the usual causes of delay.

Notice periods are the other constraint. Senior insurance executives commonly have long contractual notice periods, often with garden leave, so the gap between a decision and the appointee’s first day can be much longer than the board expects. Candidates should also be advised not to resign before approval is confirmed, which can move the resignation date and extend the gap further.

Where a senior manager function falls vacant without warning, the temporary cover rules allow someone to step in for a limited period, but the firm will still need a properly approved successor. An internal acting arrangement that the regulator does not regard as credible is a risk in its own right. Urgent SMF appointments need a different approach from ordinary interim hiring: the candidate must be approvable, available and able to pick up a Statement of Responsibilities at short notice.

Reward at carrier and Lloyd’s level is typically structured with significant variable and deferred elements, and the prudential regime expects remuneration policy to support sound risk management. Build the structure of the package, including any buy-out of deferred awards, into the offer conversation early. Our insurance search team can give current market guidance for a specific role once we understand the business and the function.

Five mistakes to avoid

• Treating insurance experience as interchangeable. Carrier, Lloyd’s, MGA and broker are different businesses. Say in the brief which is essential.
• Treating regulatory approval as a formality after the decision. It is part of the appointment, it takes time at a dual-regulated firm, and a candidate who resigns before approval is exposed.
• Confusing similar-sounding functions. SMF23 and SMF23a are different roles; a Chief Actuary and a With-Profits Actuary are different appointments. Getting the function wrong delays the application.
• Neglecting key function holders. Actuarial, risk, internal audit and compliance roles carry their own fitness and propriety expectations and are often planned late.
• Appointing technical depth without commercial breadth. Actuaries and underwriters often make excellent chief executives, but the move from technical authority to general management should be assessed deliberately rather than assumed.

Frequently asked questions

How long does a senior insurance appointment take?

Longer than an equivalent unregulated hire, and longer at a dual-regulated carrier than at an FCA-only broker or MGA. Regulatory approval, six-year regulatory references and long notice periods account for most of the difference, so plan the timetable from the intended start date backwards.

Can a candidate start before regulatory approval?

Not in a pre-approved senior manager function, other than under the limited temporary cover rules. They may join in another capacity, but the designated role cannot be performed until approval is granted.

Is SMF23a the same as a Chief Underwriting Officer?

No. SMF23 is the Chief Underwriting Officer function at an insurer or managing agent. SMF23a, Underwriting Risk Oversight, applies only to the Society of Lloyd’s and covers oversight of managing agents’ underwriting plans.

Are brokers and MGAs regulated by the PRA?

No. Insurance intermediaries, including brokers and MGAs, are solo-regulated by the FCA and fall into the core or limited scope tiers of SM&CR unless they meet the enhanced criteria. Carriers and Lloyd’s managing agents are dual-regulated by the PRA and FCA.

What is a key function holder?

Someone who runs or performs one of the key functions an insurer must maintain, including risk management, compliance, internal audit and the actuarial function. They must be fit and proper and should be planned for alongside senior manager appointments, not afterwards.

Will the SM&CR reforms remove the need for approval?

Only for some functions, and not yet. The current proposals would move roles such as the Chief Actuary to notification, while the Chief Executive, Chief Finance, Chief Risk and Chief Underwriting Officer functions stay pre-approved. Implementation is not expected before the second half of 2027.