Insurance Framework Amended: What Insurers Need to Know

• Large Risks regime and the commercialization of plans approved under General and Uniform Terms of Mandatory Use (points 23.5 and 23.6)

On September 2, 2025, the Argentine Superintendence of Insurance (SSN) issued Resolution 471/2025, which amended Sections 23.5 and 23.6 of the General Insurance Activity Regulations (RGAA), governing the Large Risks regime and the commercialization of plans approved under General and Uniform Terms of Mandatory Use, respectively.

The resolution maintained the definition of Large Risks as introduced by Resolution 384/2025, issued by the SSN on July 25, 2025 (risks exceeding a sum insured of 3,500,000 UVAs - approximately USD 3,739,000 as of the date this article-, provided they do not correspond to personal insurance), while excluding from the Large Risks regime those insurance plans submitted under the authorization mechanisms set forth in Sections 23.2, 23.3 and 23.6.

The most significant change introduced by Resolution 471/2025 with respect to the Large Risks regime is the elimination of the obligation to notify the SSN of Large Risks policies issued within 15 days of their issuance. The new regulation only requires insurers to report the issuance of policies under this regime on a quarterly basis, together with the filing of financial statements. It also simplified the documentation to be submitted, since the new regulation no longer requires the submission to the SSN of general and special conditions, a legal opinion on the contractual terms, an actuarial certification on reinsurance retention, etc., but only requires information of some specific data to be submitted in a table forma (Annex to Section 23.5).

In addition, Resolution 471/2025 simplified the reporting regime for the commercialization of plans approved under General and Uniform Terms of Mandatory Use, establishing that insurance companies wishing to market plans under this regime may do so without having to notify the SSN of their use, provided they are authorized to operate in the relevant lines of business and that the applicable regulations do not require the submission of additional documentation under the mechanisms set forth in Sections 23.2 (Plan filing) and 23.3 (Approval on a specific basis) of the RGAA.

Previously, Section 23.6 of the RGAA required insurers to submit the technical note, and the underwriting and retention policy.
 

• Repeal of the Register of Compliance Officers (Resolution 38,580/2014)

On 11 September 2025, the SSN issued Resolution 491/2025, which repealed Resolution 38,580/2014, which had created the Register of Compliance Officers for the Insurance Market.

The recitals of Resolution 491/2025 indicate that, in the opinion of the SSN, the previous regulation created an unnecessary administrative burden, given that Resolution No. 50/2011 of the Financial Information Unit (UIF) establishes that regulated entities and their compliance officers must register with the UIF.

Since the UIF is the authority responsible for analyzing, processing and transmitting information for the purpose of preventing and combating money laundering and terrorist financing, the SSN considered that the UIF is the competent authority for registering compliance officers (including those in the insurance market).

All these recent amendments seek to simplify and reduce red tape in the insurance industry.