ANALYSIS

Most writing on Bermuda’s technology codes comes from one side of the table. This comes from both.


Adam Wenham | Founder & Managing Director, Garrison


The codes

START HERE

Banks go first, fifteen months before insurers. What the board approves, what UK banks learned, and what the weeks before January can still do.

PS6/21 is the regime closest to the BMA's code, so most of the work transfers. The parts that don't are the ones carriers get wrong.

The Authority now inspects cyber risk management on-site, as well as asking about it in the filing return. A board-approved policy with no evidence the control operates is now an exposure.

Bermuda’s privacy regime has moved from education to enforcement, and PIPA is not a standalone task. It shares its evidence with OpRes and the Cyber Code.

Existing obligations already cover how carriers use AI. You remain accountable for the decision even when a vendor built the model.

Technology and change

Twelve diagnostic findings that become programmes, the lead times that mean some must start now, and where the work will be for each kind of firm.

Under the OpRes code the question is no longer whether your provider meets its service levels. It is whether it can keep your critical services running when something breaks.

Poor MGA data is not a back-office irritation. It is the point where oversight of delegated authority business fails, and it carries regulatory consequences.

Buy, build or hybrid is a governance decision with technology at its centre, and most carriers make it without independently testing fit, data, obligations or total cost.

What to do about it

Two codes in force, one binding from 2028 and a consultation all interlock. Assessed separately, the gaps that cross all of them stay invisible. The case for a single cross-domain assessment.

Most Bermuda carriers have no CTO, CIO or CISO. What they need is senior technology judgment at critical moments, and it can be bought three ways.

Where compliance evidence is going: AI to find and tag it, deterministic rules to decide it. Not software today — the workbook ships in the second half of 2027.

Garrison · Hamilton, Bermuda · adam@garrison.re
Practitioner analysis, not legal advice. More at garrison.re/analysis