By means of two resolutions, the Argentine Insurance Regulator (the “SSN”) has established new requirements for local insurance companies in relation to policies and claims registration. While one of the resolutions is centred in personal insurance policies, the other one establishes a centralized coding system to identify both insurance policies and claims.
National Registry of Personal Insurance Contracts
Resolution No. 389/2023 published in the Official Gazzette on August 23rd, 2023, introduces the National Registry of Personal Insurance Contracts (“RENASEG”). According to the SSN, this public registry is aimed to provide citizens with a complete record of their Life, Burial and Personal Accident insurance contracts in force, while also allowing beneficiaries of Life and Burial insurance contracts to know the insurance company in charge of paying the established compensations.
As per the obligations which arise for insurance companies, Resolution No. 389/2023 introduces a user’s manual (Manual de Microservicio) which lists the information that must be uploaded to the RENASEG, as well as a step-by-step guide to upload it through. This information must be submitted or updated within 24 hours of the creation of the contract or its modification.
Besides implementing the RENASEG, this resolution also states that insurance companies must now include both the identification number and tax identification number of the insured person on the specific policy conditions and individual insurance certificates.
While Resolution No. 389/2023 entered into force on the following day of its publication in the Official Gazzette, it also states that the new requirements will be mandatory once 60 days have passed from the entry into force of the resolution. Thus, insurance companies must comply with this resolution beginning October 23rd, 2023, date by which all the Life, Burial and Personal Accident insurance contracts currently in force must be uploaded to the RENASEG.
It is also important to note that the SSN has explained through its website citizens will be able to access the RENASEG by two separate means. If the users would like to retrieve the information about their insurance contracts in force, they must access the registry through the “Mi Argentina” application or website. In the case that the request is made by a beneficiary of the insurance contract or a relative of the deceased person, or any other related person, the SSN website explains that it will have to be done through the SSN’s webpage.
Unique Policy Identification Code and Unique Claims Identification Code
In addition to Resolution No. 389/2023, two additional requirements for insurance contracts and claims were introduced (with the exception of workers’ compensation insurance contracts). By publishing Resolution No. 390/2023 in the Official Gazzette on August 23rd, 2023, the SSN created the Unique Policy Identification Code (“CUIP”) and the Unique Claims Identification Code (“CUIS”).
The CUIP is aimed to uniquely identify insurance policies, its endorsements or individual insurance certificates, through a code which comprises several indicators, such as issuing company, type of insurance, internal policy number used by the insurance company, identification number of the insured party, among other indicators included in the resolution. This CUIP must be included in the specific policy conditions, individual insurance certificates, the Insurance Contracts Emission Registry and the Insurance Contract Cancellations Registry.
Similarly to the CUIP, the CUIS’ intention is to uniquely identify insurance claims through a single code, which must be uploaded by insurance companies to the Reported Claims Registry. This CUIS also comprises indicators such as issuing company, type of insurance, claim number and report number, among other indicators.
These new requirements (CUIP and CUIS) will be mandatory after 90 days from the publication of Resolution No. 390/2023 in the Official Gazzette have passed, consequently entering into force on November 22nd, 2023.
Santiago J. Sturla – Partner
Franco Blanklejder – Associate
Insuralex Argentina (Allende & Brea)
