This webpage sets out the (Regulatory) Board’s proposals and rationale for the introduction of a new Actuarial Profession Standard (APS) for insurance.
Deadline for responses: Friday 6 November 2026
Chair’s foreword
I invite you to participate in this consultation by the IFoA’s Regulatory Board (the Board) on proposals to:
- create a new APS I1, which combines the requirements of the existing APSs G1 and L1, into a single standard covering the requirements for Practising Certificates (PCs) across insurance; and
- withdraw APS G1 and APS L1.
APS G1 sets out the requirements for IFoA members performing statutory roles in the general insurance industry to hold an IFoA PC. APS L1 set out the requirements for the life insurance industry.
The IFoA now proposes to introduce a new standard, APS I1, to combine these two existing standards. The proposal is intended to achieve the following:
- consolidate the relevant provisions into a single, unified, standard, simplifying the current structure by covering all insurance actuarial roles within one document, rather than maintaining separate standards for different sectors;
- remove unnecessary duplication in PC requirements by enabling members who hold a Chief Actuary (Life) Practising Certificate to undertake Appropriate Actuary roles without needing to hold a Chief Actuary (Life, Non-Directive) PC; and
- by combining the standards, achieve a more proportionate approach to PCs for members undertaking Chief Actuary responsibilities across both life and non-life business.
The IFoA may, thereby, exercise discretion to require only a single PC where one area of work is relatively small, thereby avoiding disproportionate requirements given the size and nature of the business.
The Board welcomes comments from individual members, the organisations for which they work, other regulators and anyone else with an interest in the standards which the IFoA sets for its members.
We thank you for taking the time to consider these proposals and look forward to receiving your comments.
Sam Younger CBE
Regulatory Board Chair
Proposals
The IFoA currently maintains separate APSs for life and non-life insurance roles, which set out the requirements for members to hold a PC when undertaking specified roles. While these standards share common principles, they have developed separately over time to reflect the particular contexts of each sector.
As part of its ongoing review of the standards framework, the IFoA has identified an opportunity to improve consistency, clarity, and proportionality across its insurance standards. In particular, there is a desire to ensure a consistent approach to the Chief Actuary role, regardless of whether it is undertaken in a life or non-life context, and to bring all insurance PC roles within a single, coherent standard.
The proposed new standard, APS I1, would consolidate the provisions currently set out in the separate life and non life APSs into one unified document. This is intended to simplify the structure of the standards, making them easier to navigate and apply, while ensuring consistent expectations across comparable roles.
The consolidation also provides an opportunity to introduce greater flexibility within the PC Scheme. In particular, it would support a more proportionate approach for members who carry out work across both life and non life business. In such cases, requiring separate PCs may not always be appropriate, particularly where one area of work is relatively limited in scale or significance. The proposed framework would allow the IFoA to take these factors into account, helping to avoid disproportionate requirements while maintaining appropriate professional and regulatory oversight. It would also provide an opportunity to remove unnecessary duplication within the existing PC framework by allowing a member holding a Chief Actuary (Life) PC to act as an Appropriate Actuary without needing to hold a separate Chief Actuary (Life, Non-Directive) PC, where the existing certificate already demonstrates the required competence.
Overall, the proposed changes are intended to enhance consistency across roles, simplify the standards framework, and ensure that the PC Scheme remains proportionate and fit for purpose.
Regulatory impact assessment
The proposed introduction of APS I1 reflects a structural consolidation of the existing life and non-life insurance standards into a single, unified APS. The aim of the proposed changes is to improve consistency across comparable roles, in particular the Chief Actuary role, and to simplify the standards framework for insurance PC holders.
APS I1 will have a focused scope, covering those members who are required to hold a PC for insurance roles. However, the proposed changes are not expected to have any significant regulatory impact on members, in so far as they are limited to the:
- consolidation of existing requirements from separate life and non-life APSs into a single standard;
- alignment of provisions to ensure consistency of approach across insurance roles, including the Chief Actuary role; and
- introduction of additional flexibility to support a more proportionate application of PC requirements where members undertake work across both life and non-life business.
- removal of certain duplicative PC requirements, reducing the need for members to hold multiple certificates where competence has already been demonstrated.
For the same reason, it is not expected that there will be any significant additional costs to members, or to the organisations within which they work, including in relation to training or implementation.
The proposed changes are considered by the IFoA’s Regulatory Board to be proportionate, consistent, transparent, and targeted. They have been developed in a way that is principles-based and outcomes-focused, while maintaining appropriate professional and regulatory oversight.
The proposed standard is intended to ensure that the requirements for insurance PCs remain clear, coherent, and fit for purpose.
IFoA standards and guidance are designed to help the IFoA meet its Royal Charter objective of protecting the public interest.
How to respond to this consultation
You can respond on behalf of an organisation or provide a personal response. To provide your response please use one of the following links:
Or scan the QR code for the questionnaire for individuals:
The deadline for responses is Friday 6 November 2026.
Once the consultation has closed, the IFoA will reflect upon the feedback and publish more specific details of any changes. There will also be a period allowed before the changes come into effect so that those affected can take steps to ensure they are able to comply with the new requirements.
Contact us
If you have any queries, please contact us at regulation@actuaries.org.uk