On 25 November 2025, the FSB published a consultation report on the Scope of Insurers Subject to the Recovery and Resolution Planning Requirements (RRP) in the FSB Key Attributes. The consultation, which ended on 6 February 2026, aimed at gathering feedback on criteria to identify insurers subject to RRP requirements, on specific circumstances that should necessitate RRP requirements, as well as on FSB guidance regarding the definition of critical functions for insurers.
The FSB received 9 responses to the consultation, from both the public and the private sectors. Respondents expressed broad support for the report, while raising some concerns about potential overreach or duplication with other frameworks, and the need for clarification in certain areas.
This note summarises the feedback received on the consultation report and sets out the main changes made to the final report in order to address them.