Statement from IFoA Regulatory Board Chair, Neil Buckley, 24 July 2025
We write to confirm that following careful review of all submissions, the IFoA Regulatory Board have concluded that issues raised in the final feedback period do not amount to 鈥榝atal flaws鈥� in proposed changes to the Actuaries鈥� Code and supporting guidance. This concludes an extensive consultation process with members, employers, and other stakeholders. The changes to the Code and supporting guidance will come into effect on 25 September 2025.
On 18 March 2025, the IFoA Regulatory Board (the Board) confirmed its decision to proceed with certain changes to the Actuaries鈥� Code (Code) and existing Code Guidance.
The Board considers that these changes are in line with the IFoA鈥檚 role as a professional membership body and public interest regulator. They are also an important development in terms of the commitments set out in the IFoA鈥檚 Regulatory Policy Statement (published in 2021) that 鈥�[t]he IFoA鈥檚 regulatory role will be carried out in a way that promotes diversity, equity and inclusion鈥�, as well as the pledges set out in the .
The decision to proceed with changes to the Code and guidance follows a period of significant work and extensive engagement with members, employers, and other stakeholders (both internal and external), including two full formal consultations in 2023 and 2024 and a 鈥榝atal flaw鈥� exposure period in 2025. The large volume of engagement during the periods of consultation provided helpful and insightful input that has allowed the Board to reach a set of changes which are reflective of a proportionate, consistent, targeted, accountable and transparent approach to regulation.
The Board recognises that participants have expressed a range of views during the different consultation periods, with some strong support, but also strongly held concerns and objections voiced over the course of the process.
The Board has taken great care at each stage to examine, in-depth, the full range of feedback received, with an open mind. It recognises that this is, as some respondents have commented, a subject open to a wide range of reasonably and genuinely held beliefs and opinions. Significant time has been dedicated to this process to ensure due consideration of all feedback. The Board recognises, in particular, the principled and thoughtful nature of views expressed on all sides of this particular debate and that everybody who has taken the time to respond has done so with the best interests of the profession at heart.
At all times, the Board has considered this process, and the final outcome, to be in the public interest and reiterates that the changes are intended to promote and maintain a high standard of work and professionalism for the public and the profession.
In relation to the Board鈥檚 decision in March that they were proposing not to proceed with some of the changes (as detailed in the 2024 consultation proposal), the Board considered it appropriate to allow an 8-week final feedback period where members, employers and other stakeholders could highlight any significant objections to the proposed changes to the Code and existing Code guidance.
The 8week final feedback period closed on 13 May 2025. During this period, the Board received objections from ten individuals members as well as one note of support from an organisation employing IFoA members. There was also a response from one organisation that had previously responded confirming they now no longer had any objection. An additional webinar was also held on 1 May 2025 and attended by 46 participants.
The Board has considered each of the objections raised during the exposure period carefully and has prepared a summary of the substantive points raised. The Board has ultimately concluded that none of the points and issues raised amount to 鈥渇atal flaws鈥� such as to make further revision or review of the proposed changes necessary at this stage.
To ensure members, employers and stakeholders have sufficient time to familiarise themselves with the changes, the revised Code and Code Guidance will come into effect on 25 September 2025.
The IFoA will provide a range of support to help members understand the news requirements, including a webinar and other materials. We will share further details shortly.
The Board will continue to monitor the IFoA鈥檚 progress against its wider DEI commitments and will carry out a post-implementation review of the Actuaries鈥� Code changes in 2026, once they have been in effect for 12 months. The Board will reflect again upon the points raised during the consultations, with, at that stage, the benefit of some practical experience.
The Board wishes to take this opportunity to reiterate its thanks and appreciation to everybody who has taken the time to provide their views on the proposals over the course of the previous two consultation periods, as well as to those (fewer) respondents who elected to reply during the recent 8-week final feedback period.