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Learnings on efficacy: Insurance supervisors’ responses to COVID-19

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This guide by FSD Africa presents a regulatory response framework for insurance supervisors to manage systemic risks, developed from research across 31 countries following the impact of COVID-19 in sub-Saharan Africa. The framework consists of four phases: identifying the impact of the risk, implementing a response, monitoring efficacy, and adapting for future risks.

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  • The regulatory response framework is structured into four distinct phases: Phase 1 involves identifying and understanding the impact of the systemic risk on the regulator's mandate; Phase 2 focuses on determining and implementing appropriate responses; Phase 3 requires monitoring the efficacy of those responses; and Phase 4 involves adapting and evolving based on retroactive review.
  • Regulators have three primary avenues for responding to systemic risks: informing and engaging with the industry and public to clarify positions; making non-binding recommendations for matters not addressed in regulation or where total adherence is not strictly required; and issuing legally binding documents, which may require legislative action via a gazette and allow for sanctions such as fines.
  • To gather information during a crisis, regulators utilize bilateral communication with entities, engagement with industry associations, routine quarterly and annual reports, and additional reporting requirements such as solvency stress tests or targeted annexures. While many supervisors had online data submission platforms before the pandemic, some still rely on small teams for data analysis, which can result in a timeline of almost a year and a half to identify current trends.
  • The guide identifies several critical learnings for efficacy: regulators should be proactive to create market certainty but avoid overreacting with overly restrictive statements; they must balance the need for timely data with the risk of overburdening the industry; and they should utilize a Risk-Based Supervision (RBS) approach to ensure proportionate responses.
  • Phase 3 (monitoring efficacy) is not consistently implemented across regulators in sub-Saharan Africa, though it is noted as a major area of development following COVID-19. Effective monitoring allows regulators to change course and avoid negative consequences of their responses.
  • Insurance supervisors are specifically concerned about future systemic risk events including climate risks, cyber-security and data protection, terrorism, and political unrest.

Cite the original document

APA
FSD Africa (n.d.). Learnings on efficacy: Insurance supervisors’ responses to COVID-19. https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-supervisors-regulatory-response-infographic-08.02.22.pdf
Chicago
FSD Africa. Learnings on efficacy: Insurance supervisors’ responses to COVID-19. n.d. https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-supervisors-regulatory-response-infographic-08.02.22.pdf.
Wikipedia
{{cite report |author=FSD Africa |title=Learnings on efficacy: Insurance supervisors’ responses to COVID-19 |url=https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-supervisors-regulatory-response-infographic-08.02.22.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{fsdafricandlearnings, author = {{FSD Africa}}, title = {{Learnings on efficacy: Insurance supervisors’ responses to COVID-19}}, institution = {FSD Africa}, url = {https://fsdafrica.org/wp-content/uploads/2025/05/Insurance-supervisors-regulatory-response-infographic-08.02.22.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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