Typology of insurance supervisory authorities

The typology of insurance supervisory authorities refers to the classification of organizations or entities whose role is to monitor, regulate and supervise the insurance sector in a given country or internationally. These authorities ensure the stability of the market, the protection of policyholders and the compliance of industry players.

This supervision takes many forms. It may involve oversight carried out by:

• independent administrative authorities,
• supervisory ministries,
• regional or community authorities,
• separate entities, in cases of dual control,
• market authorities,
• decentralized administrative authorities,
• professional bodies with delegated competence.

Control by independent administrative authorities

Insurance supervisory authorities are independent bodies set up by virtue of law or decree. They are generally endowed with legal personality and financial autonomy, which guarantees their operational independence.

This configuration enables them to manage their own budgets, set out their own internal procedures and fulfill missions clearly defined by law.

They carry out a public service mission, beyond the direct control of the government.

These Legally and financially independent entities have powers of control, sanction and regulation. Their mission includes prudential supervision of the solvency and capital adequacy of market players.

Case in point: Morocco's Supervisory Authority of Insurance and Social Welfare (ACAPS).

Established in 2016 by law no. 64-12, the Supervisory Authority of Insurance and Social Welfare (ACAPS) is the entity tasked to regulate and supervise the insurance sector in Morocco.

Its main missions include:

• The technical and prudential supervision of insurance and reinsurance companies,
• The organization and structuring of the insurance market,
• The protection of consumer interests. The authority requires that citizens be well informed about insurance offers and terms and treated fairly,
• The guarantee of the rights of members, affiliates and beneficiaries,
• The standardization and regulation of the sector,
• The fight against money laundering and the financing of terrorism.

The supervisory body is committed to facilitating public access to information and services related to the insurance and social welfare sectors.

ACAPS is overseen by the Board of Directors, which publishes an annual report submitted to the relevant authorities.

Control by the supervisory ministries

These bodies are part of the public administration, often attached to a ministry, with their managers being appointed by the government and subject to civil service rules.

In such cases, the supervisory body sometimes takes the form of an insurance department within a ministry, generally the Ministry of Finance, as is the case in Algeria, where the Insurance Supervisory Commission (CSA), established under article 209 of Ordinance 95-07, amended by article 26 of Law 06-04, is attached to the Ministry of Finance.

CSA's main mission is to protect the interests of policyholders and beneficiaries of insurance contracts. At the same time, it actively strives to promote and develop the national insurance market, contributing to its expansion and consolidation within the economy.

Supervision by a regional or community authority

In certain regions or economic and political zones, insurance supervision is sometimes exercised by two entities: a national entity and a supranational entity.

In such cases, the supranational authority operates in close association with local supervisory authorities. The division of powers and levels of control vary from one regional grouping to another.

Two organizations of this type are worth mentioning: CIMA in French-speaking West and Central Africa, and EIOPA in the European Union.

• The Inter-African Conference on Insurance Markets (CIMA)

Established on 10 July 1992, and effective since 15 February 1995, CIMA is the community organization governing the insurance industry in 13 French-speaking African founding member countries. Guinea Bissau, a Portuguese-speaking country, joined CIMA in 2002, bringing the total number of member States to fourteen.

CIMA has a common code (the CIMA Code) applicable to all member countries. As such, national supervisory authorities have, among other duties, the task of applying the CIMA Code on their territory.

CIMA has extensive supervisory and control powers over insurance companies operating in member countries. It is in particular involved in:

• granting and withdrawing licenses for insurance companies,
• monitoring solvency and compliance with prudential standards,
• imposing sanctions in the event of non-compliance,
• defining and amending rules applicable to the entire market (CIMA Code).
• The European Insurance and Occupational Pensions Authority (EIOPA)

financial supervision revealed by the 2007-2008 crisis. Its main role is to ensure a high, effective and consistent level of regulation and supervision in the insurance and occupational pensions sector across the European Union.

EIOPA was established in 2011, taking over the functions of the Committee of European Insurance and Occupational Pensions Supervisors (CEIOPS).

It operates independently but remains accountable to the European Parliament, the Council of the European Union and the European Commission for the proper functioning of the market.

EIOPA is part of the European system of financial supervision and has a regulatory and supervisory role at the European level. National authorities are responsible for the direct supervision of insurance and pension organizations at the national level, while actively participating in EIOPA's work.

EIOPA's main missions:

• ensure public interest by improving consumer protection and restoring confidence in the financial system,
• guarantee a high, effective and consistent level of regulation and supervision in the insurance sector within the European Union,
• prohibit or temporarily restrict certain financial activities that threaten the proper functioning, integrity of financial markets or stability of the financial system in the Union, as per the cases and conditions provided for by legislation,
• protect the stability of the financial system, the transparency of financial markets and products, and the protection of policyholders, pension scheme members and beneficiaries,
• guarantee a level playing field and strengthen the international coordination of supervision,
• develop and implement a single European set of regulations applicable to all financial institutions in the internal market,
• provide advice to EU institutions on the regulation and supervision of insurance, reinsurance and occupational pensions, as well as on corporate governance, auditing and financial reporting,
• ensure supervisory convergence between Member States.

The European Insurance and Occupational Pensions Authority (EIOPA) oversees and coordinates insurance and pension supervision across the 27 European Union countries.

Supervision by market authorities

Some financial regulatory authorities have a broader scope than insurance (including banks, financial markets, etc.). These bodies are distinctively renowned for covering a broad financial spectrum.

They are usually independent administrative authorities at a high level in the state hierarchy. This is the case, for example, in China, Japan, Saudi Arabia, Bahrain, the United Arab Emirates and Turkey.

These organizations showcase a degree of administrative and financial autonomy from government ministries, although they remain under the supervision of the State. They are often established by virtue of an organic law that defines their powers and operations. Their directors are appointed for specific terms.

In China, the independent administrative authority, the NFRA, is placed under the direct authority of the State Council, the supreme executive body.

Established on 10 March 2023, the National Financial Regulatory Administration (NFRA) oversees China's insurance market. The NFRA replaced the China Banking and Insurance Regulatory Commission (CBIRC). It has also integrated functions previously belonging to the People's Bank of China (PBC) and the China Securities Regulatory Commission (CSRC).

Cette réorganisation réunit la surveillance financière sous une seule entité.

Les principales attributions de la NFRA (National Financial Regulatory Administration) incluent :

• l'élaboration et la mise en œuvre de politiques et de réglementations pour les secteurs bancaires et assurance,
• la surveillance de la solvabilité et de la conduite des acteurs du marché,
• l'approbation des fusions-acquisitions,
• la gestion des fonds de garantie financière,
• la supervision des investissements des assureurs,
• la protection des consommateurs,
• la gestion des données,
• la supervision technologique.

In Japan, the Financial Services Agency (FSA) is the supervisory authority for the insurance industry. Established under Law No. 130 of 1998, it came into force in 2020.

This government agency is a regulator operating under the aegis of the Minister of State for Financial Services, and is responsible for overseeing not only insurance, but also the banking and stock exchange sectors.

The FSA is also tasked with ensuring the stability of Japan's financial system by regulating, inspecting and monitoring all financial activities, including those of insurance companies.

In Saudi Arabia, the regulation of the insurance sector has undergone a recent change. Since 23 November 2023, supervision and control of the sector have been transferred from the Saudi Central Bank (SAMA) to the Insurance Authority (IA).

The IA is an administratively and financially autonomous governmental entity, reporting directly to the Prime Minister. Its scope includes regulating and supervising the insurance sector, improving its efficiency and promoting its financial autonomy. It also aims to reinforce the principles of the insurance contractual relationship, ensure the protection of the rights of beneficiaries and policyholders, and optimize risk management within the sector.

In May 2025, the Saudi Insurance Authority (IA) revoked the operating licenses of 28 brokerage companies and insurance agencies operating on its territory. This decision is part of a series of remedial measures designed to enhance the sector's efficiency, improve customer confidence, protect policyholders' rights and promote financial stability.

In Bahrain, the Central Bank of Bahrain (CBB) regulates and supervises the entire financial sector, including insurance.

Set up on 6 September 2006, under the CBB and Financial Institutions Act 2006, it succeeded the Bahrain Monetary Agency (BMA).

The BMA had previously regulated and supervised the entire financial sector since 1973, and the insurance sector since 2002. The CBB's supervisory responsibilities in the insurance sector include licensing and supervision.

In the United Arab Emirates, the Central Bank of the United Arab Emirates (CBUAE) regulates and supervises the insurance sector under Federal Law No. 25 of 2020. This law transferred regulatory, supervisory, licensing and enforcement functions for the insurance sector to the CBUAE.

Prior to 2020, insurance market supervision was carried out by a separate entity, the Insurance Authority (IA). The merger of the IA with the CBUAE granted the new entity full responsibility for supervising the insurance sector.

In Turkey, the Insurance and Private Pension Regulation and Supervision Agency (SEDDK) regulates the insurance and private pension sectors. Established by Presidential Decree no. 47 of 18 October 2019, it is an independent administrative agency with public legal personality and financial autonomy.

In 2020, the "General Directorate of Insurance" of the "Ministry of Treasury and Finance" and the "Presidency of the Insurance Supervisory Board" were merged into SEDDK with the aim of accelerating the contribution of the insurance and private pension sectors to the Turkish economy and ensuring more dynamic regulation and supervision.

Twin Peaks Regulation

In some countries, two regulatory bodies are responsible for supervising the insurance sector, or even the entire financial sector. This system makes a clear distinction between the two main missions of the supervisory authority:

• prudential supervision, to ensure the financial soundness of institutions,
• supervision of market practices and consumer protection.

Both bodies discharge their duties in close coordination, complementing each other.

In the financial sector, Australia was the first jurisdiction to impose this regulatory architecture. The model has since been adopted by several other countries, including the UK and South Africa.

Insurance supervision in the UK

Prior to 2013, insurance regulation in the UK was carried out by the Financial Services Authority (FSA) as part of a tripartite supervisory arrangement, which also included the Bank of England and the Treasury.

In 2013, the FSA was replaced by dual supervision exercised by two new authorities: the Prudential Regulation Authority (PRA), reporting to the Bank of England, and the Financial Conduct Authority (FCA).

Each body has its own missions:

• The Prudential Regulation Authority (PRA)

Primarily responsible for prudential supervision, the PRA ensures that insurers operating in the United Kingdom do not pose a risk to the stability of the financial system. It ensures that insurance companies have sufficient financial stability to meet their commitments to policyholders.

In the event of an insurer's failure, the PRA must ensure that policyholders are protected and not affected in any way.

• The Financial Conduct Authority (FCA)

The FCA is primarily responsible for protecting consumers by combating abusive practices (deception, forced sales, fraud) and ensuring that financial products and services (loans, insurance, investments, etc.) are transparent and fair. It imposes strict rules on insurance companies to prevent prejudice to policyholders and beneficiaries of contracts.

Insurance supervision in South Africa

The current financial sector supervision system in South Africa draws inspiration from the UK model. Since 1 April 2018, when the Financial Sector Regulation Act (FSR Act) of 2017 came into force, South Africa has been applying the Twin Peaks supervision model.

This system is based on two separate authorities: the Prudential Authority (PA) and the Financial Sector Conduct Authority (FSCA). Each body has a specific role in regulating the financial sector, including insurance.

• The Prudential Authority (PA)

Under the umbrella of the South African Reserve Bank (SARB), the PA is responsible for prudential supervision. It monitors the financial soundness of insurance companies to ensure their ability to meet their commitments.

The PA plays a central role in preserving the stability of the financial system by identifying and limiting systemic risks.

• The Financial Sector Conduct Authority (FSCA)

The FSCA, tasked with the regulation of market practices and protection of consumers, ensures that insurance companies treat their customers fairly, transparently, and equitably. It also supervises financial markets and develops programs to improve the financial literacy of South Africans.

This dual-tier system allows for more specialized and consistent regulation of the insurance sector, clearly distinguishing between the monitoring of institutions' financial soundness and the supervision of commercial behavior.

Oversight exercised by decentralized autonomous entities: The case of the United States

The United States features a system of decentralized powers. The federal government is reduced to a coordinator whereby control of the insurance sector is mainly exercised at the State level, with each State having its own supervisory body, often called the “Insurance Department,” “Division of Insurance,” or “Office of Insurance.”

Until May 2025, there were 56 autonomous supervisory authorities, each headed by a Commissioner appointed by the Governor of the Federal State or elected.

These regulatory authorities fall under the local executive branch, whose title varies from State to State: Office of the Governor, Department of Commerce, Financial Service Commission, etc.

The laws and regulations enacted by each regulatory body form the legal basis for insurance law in the state concerned. Each state has, therefore, complete control over the regulation and supervision of the insurance sector within its jurisdiction.

Oversight by independent administrative authorities

The regulation and supervision of the sector may also be carried out by other players in the insurance market, although they have no direct power.

Insurance associations and federations can exert regulatory influence through active participation in debates and law-making processes.

Some oversight tasks may be partially entrusted to professional or mutual organizations. This is the case, for example, for the management of the green card for motor vehicles in Europe, the orange card for motor vehicles in Arab countries, and the brown card in the countries of the Economic Community of West African States (ECOWAS).