The UK government and European Commission have been busy with their own plans for changes to insurance regulation as laid down by the Solvency II Directive. EU insurers with UK business that entered in the UK’s temporary permissions regime and are now going through the process of becoming authorised as a branch in the UK will be regulated by the new insurance regime introduced by the UK government (Solvency UK). Likewise, UK insurers that have business in EU member states will be regulated by the member state in which they become authorised (Solvency II). Although it is too soon to say to what extent the Solvency II regimes in the UK and EU will diverge, it is inevitable that over time the rules will change and insurance and reinsurance companies with a presence in both jurisdictions will need to get to grips with two ‘similar, but different’ regulatory regimes.