Insurance regulators’ response to COVID-19

This report by Cenfri and FSD Africa analyzes how insurance regulators across 31 sub-Saharan African countries responded to the COVID-19 pandemic. It proposes a four-phase regulatory response framework—Identify, Determine/Implement, Monitor, and Adapt—to help supervisors manage future systemic risks such as climate change and cyber-security threats.

• The report proposes a four-phase regulatory response framework for systemic risks: Phase 1 involves identifying and understanding the risk impact; Phase 2 focuses on determining and implementing responses; Phase 3 monitors the efficacy of those responses; and Phase 4 involves adapting and evolving based on learnings.
• Regulators face significant trade-offs between different mandates during crises, specifically balancing prudential financial soundness against consumer protection. For example, the Insurance Regulatory Authority (IRA) in Uganda prioritized policyholders by requiring insurers to cover COVID-19 health claims despite policies generally excluding pandemics.
• Relying solely on routine quarterly and annual reports is insufficient for understanding systemic risks because of the slow speed of data collection. Regulators in Eswatini found that some critical information cannot be captured via quarterly returns, and others were unable to determine the mid-term impact of the pandemic while waiting for 2021 audited reports.
• Risk-based supervision (RBS) proved more effective than compliance-based requirements for monitoring industry weaknesses. Regulators in Namibia, Zambia, and Zimbabwe noted that compliance-based systems made it harder to identify entities in distress during the pandemic.
• Regulatory responses generally fall into three categories: informing and engaging (non-binding communication), making non-binding recommendations (such as suggesting the suspension of shareholder dividends in South Africa), and issuing legally binding documents (such as the IRA in Uganda's guidelines on business conduct).
• The adoption of Supervisory Technology (Suptech) can shift monitoring from a 'backward-looking' approach to a predictive and proactive process, reducing compliance costs for regulated entities and increasing efficiency for regulators.
• Coordination between different regulatory bodies is essential to avoid uncertainty. In South Africa, the Prudential Authority (PA) and Financial Sector Conduct Authority (FSCA) issued joint communications on business interruption insurance to ensure cohesion between prudential and market conduct mandates.
• Regulators used the pandemic to strengthen industry preparedness by requiring business continuity plans (BCPs) and stress tests. The Pensions and Insurance Authority (PIA) in Zambia mandated stress tests on liquidity, capital adequacy, solvency, and cash flow.
• Phase 3 (monitoring efficacy) was the least consistently implemented phase across the studied jurisdictions, representing a major area for future development for sub-Saharan African regulators.
• Regulators are now identifying new systemic risks to prepare for, including climate change (affecting liability and transition to low-carbon economies), cyber-security (increased by digital migration), and political unrest (such as the 2021 terrorist attacks in Kampala, Uganda).

APA

Beyers, N., Scribante, K., & Gray, J. (2022). Insurance regulators’ response to COVID-19. FSD Africa. https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-regulators-response-to-COVID-19_March-2022.pdf

Chicago

Beyers, Nichola, Karien Scribante, and Jeremy Gray. Insurance regulators’ response to COVID-19. FSD Africa, 2022. https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-regulators-response-to-COVID-19_March-2022.pdf.

Wikipedia

{{cite report |last1=Beyers |first1=Nichola |last2=Scribante |first2=Karien |last3=Gray |first3=Jeremy |title=Insurance regulators’ response to COVID-19 |publisher=FSD Africa |date=March 2022 |url=https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-regulators-response-to-COVID-19_March-2022.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{beyers2022insurance, author = {Beyers, Nichola and Scribante, Karien and Gray, Jeremy}, title = {{Insurance regulators’ response to COVID-19}}, institution = {FSD Africa}, year = {2022}, month = mar, url = {https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-regulators-response-to-COVID-19_March-2022.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }