SUSEP prepares manuals for the implementation of Open Insurance and starts gathering suggestions from the market

In order to continue the implementation of Open Insurance in the Brazilian insurance sector, the Superintendence of Private Insurance (SUSEP) made available on May 17, 2021 the manuals that detail the technical requirements and procedures for the operationalization of Open Insurance in Brazil, setting out a specific period for the market to present suggestions.

After addressing the topic of Open Insurance regulation in the Draft Resolution and Circular that were under public consultation until May 22, 2021 through Notices No. 12 and 13/2021, SUSEP is now gathering suggestions from the market regarding the manuals produced with the collaboration of the Brazilian Central Bank, containing rules for adaptations to the new reality of the Open Insurance initiative and services, whose first implementation phase should be completed by December 2021.

The draft of the Circular that regulates the matter had established that the rules of this new system would be divided into five distinct manuals, named (i) Scope of Open Insurance Data and Services Manual; (ii) Open Insurance APIs Manual; (iii) Open Insurance Governance Structure Services Manual; (iv) Open Insurance Security Manual; and (v) Open Insurance Customer Experience Manual.

However, considering the current needs and the initial implementation phase of the system, only the manuals provided for in items i to iv of the above paragraph have been produced at this point, having as their aim, respectively, to ensure the level of detail and standardization required for each of the data listed in the new Open Insurance regulations, to define the specifications of the APIs required for data sharing, as well as the security, infrastructure and management rules of this new technology.

Considering the similarities and compatibility between the Open Insurance and Open Banking environments, which seek to regulate and operationalize the Brazilian General Data Protection Law (LGPD) in these two important economic segments, the manuals produced by SUSEP have a similar structure to those presented in the Brazilian Central Bank’s Normative Instruction Nos. 95, 96, 98 and 99.

The Customer Experience Manual, in turn, will only be made available at a later time, since it is part of the second phase of the Open Insurance implementation project, scheduled to occur in May 2022.

Suggestions may be sent to the Regulator until June 17, 2021, through the email openinsurance@susep.gov.br, and must necessarily contain indications of (i) the name and affiliation of the author of the suggestion; (ii) the manual to which the suggestion is being made; and (iii) the section of the document.

Demarest’s Insurance and Reinsurance team will monitor the development of these public consultations until the publication of the final text of the manuals, and will be available to provide any clarifications on the matter.