UK Life & Annuity market: Critical themes for CEOs to navigate in 2026
UK Life & Annuity market: Critical themes for CEOs to navigate in 2026
29 Jan 2026
The UK life and annuity sector has a broadly agreed strategic direction: scale where it matters, simplify where it hurts, deploy capital productively, modernise technology, and maintain regulatory credibility.
Senior insurance leaders are faced with a convergence of pressures, such as growing competition in pension risk transfer, tougher regulatory scrutiny of capital and liquidity, and growing concern that legacy complexity is undermining resilience.
Differentiation will come from those willing to make bold decisions - to actively manage structural change rather than simply monitor it.
In this edition of XPS Insurance Watch, we explore how these pressures are shaping the sector and highlight six key themes that will define the year ahead, outlining what's happening and why it matters.
Three realities dominate the year ahead:
1 |
Competition in the pension risk transfer market has changed structurally: |
2 |
Regulators are tightening around structural risk: The regulatory landscape for insurers is transforming, focusing on operational resilience and innovative capital structures. Firms must ensure governance is transparent and balance strategic capital deployment with strong operational frameworks to meet evolving regulations and safeguard stability. |
3 |
Legacy complexity has become the enemy of resilience: Product sprawl, operating model fragmentation, opaque capital structures and uncontrolled AI adoption are increasingly viewed by executives, boards and regulators as risks that require active intervention, not incremental management. |
2026 promises another exciting chapter for the
UK Life & Annuity market, demanding transformative
leadership to drive innovation, sustain competitive
advantage, streamline business models, and bolster
operational resilience.David Honour
Head of Insurance Consulting
Contact us
Six key themes for 2026
The platform era of UK life insurance
What’s happening
The UK life and annuity market has entered a phase of platform-driven competition, accelerated by major transactions:
- Athora acquiring Pension Insurance Corporation
- Brookfield Wealth Solutions acquiring Just Group
- JAB Holding acquiring Utmost Life & Pensions
These transactions share a common thesis: insurance as a long-duration capital platform, underpinned by asset origination, permanent capital and operating leverage.
Why it matters in 2026
For CEOs, this reframes the competitive question from “are we well capitalised?” to:
- Do we have robust asset sourcing at scale?
- Are we maximising the return on capital for investors?
- Are we operationally efficient and scalable?
Firms without scale or a clearly articulated niche face increasing strategic pressure.
Strong demand, tougher differentiation
What’s happening
In 2025, more moderate transaction volumes (c. £40bn) contrasted with a record number of transactions and increased bidding intensity, particularly in the small-to-mid market. Structural demand for pension risk transfer remains strong, but trustees and sponsors now have more credible alternatives, including run-on strategies, phased approaches and surplus management.
The Stagecoach transaction is a useful marker for 2026: the £1.2bn Stagecoach Group Pension Scheme agreed an innovative run-on and sponsor substitution structure under which Aberdeen Group became the sponsoring employer. This illustrates that well-funded schemes are increasingly selective about how and when they de-risk, and that insurers now compete with non-insurance endgame options.
Why it matters in 2026
The basis of competition has shifted:
- Execution certainty is increasingly as important as headline pricing
- Operational credibility (administration, transition, member experience) materially influences trustee decisions
Winning BPA business in 2026 is less about “price at any cost” and increasingly about innovation, certainty and operational scaling.
Innovation under scrutiny
What’s happening
The PRA has sharpened its focus on how insurers create capacity, not just how much they deploy. This includes heightened attention to:
- Basis risk and collateral mismatch
- Inherent risk and regulatory arbitrage in the use of FundedRe
- The growing role of alternative capital structure
At the same time the PRA has several initiatives targeted to support competition and growth including:
- Launch of the Matching Adjustment Investment Accelerator initiative
- Implemented reforms to the Insurance Special Purpose Vehicles regime to widen the types of insurance-linked securities structures available
- Consultation on the new UK captive regime aimed to launch in 2027
- Discussion on Alternative Life Capital options, with the intention to remove barriers to patient capital entering the sector
Why it matters in 2026
Capital structuring remains a legitimate strategic lever — but only where:
- Risk transfer is genuine and well understood
- Liquidity and collateral are robustly managed
- Boards can clearly articulate the trade-offs involved
CEOs should assume that opaque or weakly governed structures will face increasing supervisory friction
Simplification becomes unavoidable
What’s happening
As Consumer Duty changes begin to embed, we see an increasing focus on broader product rationalisation, with a focus on addressing legacy products. Successful programmes will require clear Board ownership, early agreement on risk appetite and focus on customer outcomes.
- Improve customer outcomes
- Reduce operating cost
- Address legacy products
Why it matters in 2026
Product rationalisation is emerging as one of the highest-impact CEO levers:
- Fewer product variants reduce cost and error
- Simpler propositions are easier for consumers to understand
- Legacy clean-up directly supports operational resilience
2026 is where firms move from analysis to decisive simplification.
Operational resilience
What’s happening
With rising geopolitical tensions and pressures on sovereign debt markets, the PRA expects continued focus on the operational resilience of firms.
Liquidity reporting
Implementation of PRA liquidity reporting (PS15/25) by 30 September 2026 forces
insurers to industrialise:
- Cashflow forecasting with no or 1 day lag
- Collateral mobilisation
- Data lineage and controls
This is a treasury, risk and technology challenge — not just a regulatory reporting exercise.
Solvent exit planning
By 30 June 2026, firms must meet PRA expectations on solvent exit planning (PS20/24).
Insurers should treat solvent exit planning as a strategic stress test of operability, covering:
- Operational dependencies and outsourcing concentration
- Mobilisation of liquidity resources
- The ability to execute a transfer or run-off without destabilising customers or counterparties
Why it matters in 2026
Taken together, these requirements and emerging analysis will test whether a firm can successfully execute its strategy under stressed conditions, not just on paper.
From oversight to enablement
What’s happening
AI is rapidly moving from pilot to embedded use across underwriting, servicing, analytics and decision support. At the same time, boards and regulators are increasingly focused on:
- Explainability and fairness
- Model risk beyond traditional actuarial models
- Data leakage and third-party concentration risk
Why it matters in 2026
Modern risk functions will be defined by:
- Speed: near-real-time insight and horizon scanning, not retrospective reporting
- Breadth: AI and data models fully integrated into model risk frameworks
- Control: clear ownership, human-in-the-loop governance and auditability
AI without governance creates conduct and operational risk. Governance without enablement creates competitive drag.
Key questions shaping CEO decision‑making in 2026
CEOs and boards must actively manage the key themes we’ve outlined, not just monitor them. Asking these six key questions will help shape decision-making.
1 |
Where do we compete — platform scale, specialist propositions, or capital/structures? |
2 |
Are we operationaly efficient to support higher volume of transations? |
3 |
Can we meet solvency exist and liquidity reporting requirements, and what weaknesses must we address? |
4 |
What capital, reinsurance, and alternative structures make sense to leverage now given regulatory initiatives and scrutiny? |
5 |
What product rationalisation decisions will we take to improve outcomes and unit economics? |
6 |
How do we utlise AI to drive insight while meeting risk & compliance standards? |
Wider themes CEOs should note
These are not standalone topics - they cut across every theme previously mentioned.
|
|
Productive finance and the UK growth agenda: continued pressure on insurers to invest in productive assets, with execution and concentration risk front of mind. |
| Cyber and operational resilience: increasingly table-stakes, but failures will be binary and reputational in impact. |
|
| Embed technology and data at scale – with initiatives that clearly demonstrate efficiency gains, better customer outcomes, and improved risk management. The era of small pilots is ending; measurable impact is expected. | |
|
ESG and sustainability risk: under PRA SS5/25, ESG — particularly climate and transition risk — is now a core prudential issue. Firms are expected to evidence how sustainability risks are governed and integrated into risk management, investment decisions and capital assessment. This shifts ESG from disclosure-led activity to demonstrable discipline. |
Find out more
For more information, please get in touch with David Honour. Alternatively, please speak to your usual XPS contact.
- Register for events
- Join our mailing list
Register for events
We enjoy hosting a wide range of events for pension scheme trustees, corporate sponsors, independent trustees, and pensions professionals.
Join our mailing list
Keep up to date with our latest news and views including pension briefings, XPS insights, reports and event invitations.