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.