Clifford Chance

Insurer resolution: how do the new UK and EU regimes compare?

17 February 2023

Both the UK and EU have proposed new resolution regimes for failing (re)insurers based on international standards and their existing regimes for bank resolution. As a result, the proposed UK Insurer Resolution Regime (IRR) and the proposed EU Insurance Recovery and Resolution Directive (IRRD) have much in common, albeit with some key differences.

This briefing provides a high-level comparison of the IRR, the IRRD and the UK and EU regimes for bank resolution, highlighting the main differences.

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