The Northern Ireland Assembly is currently considering the Age Discrimination (Goods, Facilities and Services) Bill, introduced by independent MLA Claire Sugden. Equality law is devolved to the Northern Ireland Assembly and so the Equality Act 2010 does not apply there. This Bill is intended to close some of this gap. 

Given that age is a key factor for insurers in assessing risk, as well as for pension and annuity providers who use age for underwriting, we have been engaging on the Bill to stress the importance of mirroring the exceptions for financial services in Great Britain. 

Clause 15, which relates to exceptions for financial services, is the important one for ABI members. 

As drafted, the Bill requires the Northern Ireland Executive to have regard to reliable actuarial or statistical data or other relevant underwriting or commercial factors when making regulations for financial services. However, it does not provide a “blanket exemption”. Instead, the Executive would have a 12-month period from Royal Assent to agree any exceptions. 

This risks putting Northern Ireland out of step with Great Britain, where the Equality Act 2010 (Age Exceptions) Order 2012 allows financial services providers to use age as a factor in assessing risk provided this information is relevant and based on a reliable source. Removing or narrowing these exceptions could have unintended consequences for all consumers and for providers operating in the Northern Ireland market. 

Insurance featured prominently in the Second Stage debate in the Assembly, with a particular focus on motor and travel insurance for both older and younger consumers. Claire Sugden MLA emphasised that she wants to avoid unintended consequences for the affordability or availability of insurance, while explaining that she has deliberately gone further than legislation in Great Britain to prevent what she referred to as unjustifiable age discrimination in some cases. 

The Bill received broad cross-party support at Second Stage, when Members consider the principles rather than the detail of proposed legislation. However, several Assembly Members raised the need to further consider the financial services exceptions, expressing some concerns about practical implementation, interaction with existing financial services regulation, alignment with Great Britain and unintended consequences for consumers and markets. 

Against this background, we expect exemptions for financial services to be a significant focus of Committee Stage scrutiny. 

• October 2026: Bill passes Second Stage and moves to Committee Stage 
• Early November 2026: Committee call for written evidence expected 
• Late 2026 / early 2027: Committee consideration of evidence, including evidence sessions 
• Spring 2027: Committee report and Bill returns to the Assembly for further debate and vote, including on any proposed amendments 
• Mid-March 2027: Deadline for achieving Royal Assent 

While the timetable is tight, there is a route to the Bill achieving Royal Assent before the upcoming Assembly election. 

We responded to the Bill consultation earlier this year and met with Claire Sugden MLA to highlight the importance of preserving age-related pricing, the evidence supporting its use and the existing protections against unjustified age discrimination. 

We are currently reviewing the legal and regulatory implications of the Bill and plan to respond to the Committee’s call for evidence. Our submission will cover general insurance, health & protection and long-term savings products, and will stress the need for certainty in the legislation so that insurers and long-term savings providers can continue to use age to assess risk where supported by actuarial evidence, statistical data and other legitimate risk factors.  

We also expect to be asked to give oral evidence to the Committee in January. 

Throughout this process, we will continue to engage closely with the Northern Ireland Executive and the Committee, as well as other stakeholders, including HM Treasury and relevant trade associations. 

We are including information to relevant ABI member committees and will keep firms updated as the Bill progresses. We’d welcome any feedback on key considerations and concerns.