New Public Registry of Life Insurance Contracts and Uniform Codes to Identify Policies and Claims

On August 18, 2023, the Argentine Superintendence of Insurance (SSN) issued Resolution 389/2023. The SSN considered it was necessary to respond to the large number of queries received about life, burial, and/or personal accident insurance policies taken out by persons who later passed away.

The SSN consequently created the National Registry of Insurance Contracts for Natural Persons (RENASEG), to allow insureds to obtain information on their insurance policies in force and to provide other users with information on the existence of insurance policies facilitating the appointed beneficiaries’ collection of benefits. The SSN also made it compulsory to include insureds’ CUIL numbers (tax identification numbers) both in the particular conditions (policy front) and in the certificates of coverage of group policies.

The RENASEG will file information on life, burial, and personal accident contracts entered into by natural persons. The insurance companies operating in these lines will provide this information (registrations, cancellations, and changes) to the RENASEG on a daily basis, through an online system called "Micro-servicio".

The obligations and requirements arising from the creation of the RENASEG will become mandatory 60 days after the Resolution becomes effective, i.e., on October 30, 2023. By that date, insurers must have uploaded information on all insurance policies in force.

The Resolution does not clarify how and under which conditions policyholders and other users will be able to access RENASEG information. However, according to the information available on the SSN's website, policyholders will send their queries about their own insurance policies through the “Mi Argentina” app. Other parties will have to send their queries through the SSN website (a tool not yet available). Users will have to first validate their identities.

The website will validate with the National Register of Individuals (RENAPER) if the alleged insured is actually deceased. The RENASEG will then provide the following information on the deceased insured: name, ID number, and CUIL, insurance policy numbers, and the names of the insurance companies.

On August 22,^, 2023, the SSN also enacted Resolution 390/2023. The SSN found that it was necessary to establish "uniform rules for identifying policies, endorsements, renewals, certificates, and reported claims" to implement more accurate controls. The SSN then updated the regulatory provisions concerning the identification of insurance policies and claims.

The SSN consequently created the Uniform Policy Identification Code (CUIP), the implementation of which will be mandatory for all lines and sub-lines, except "Labor Risks". The Resolution therefore amends section 25.1.1.1.1. of the General Regulations of the Insurance Activity (RGAA), adding to the provisions of subsection k) the obligation to inform the CUIP among the minimum contents to be included in the particular conditions of each policy.

The SSN also made it mandatory to include the CUIP in all policy fronts, renewals, and endorsements, certificates, payments delivered by policyholders to the insureds under group policies to the corresponding insured, and in the Registry of Issued Policies and the Registry of Policy Cancellations. This Resolution approved the “Annex to section 37.4.2.1.1.”, which provides the guidelines to structure the CUIP.

Besides, through this same Resolution, the SSN created the Uniform Claims Identification Code (CUIS), to be included in the Registry of Reported Claims, according to the amendment introduced to section 37.4.2.1.2. of the RGAA. The structure of the CUIS will contemplate the guidelines in "Annex to section 37.4.2.1.2”.

This Resolution will become mandatory within 90 calendar days from its publication in the Official Gazette, i.e., on November 21, 2023.