Consistent with the common law of contract, an insurer is not able to transfer the burden of its obligations under a contract of insurance without the consent of the policyholder. A novation agreement between the original insurer, the policyholder and the substitute insurer is, as a general rule, required to effect such a transfer. As an exception to this rule, an insurance business transfer scheme under Part VII of the Financial Services and Markets Act 2000 (FSMA 2000) provides a process by which an insurer may transfer the whole or part of its business, subject to certain conditions, without obtaining the consent of individual policyholders. The UK has had a regime for transferring portfolios of business for some time. Earlier procedures under the Insurance Companies Act 1982 differed in the case of long-term insurance (essentially life, annuity, permanent health and pension business) and general insurance business. In the former case, a court application was required, whereas for general insurance, only the approval of the regulator was needed. In either case, a difficulty