13 January 2004

ROYAL & SUN ALLIANCE INSURANCE GROUP PLC: HOLDING IN COMPANY

A letter from Fidelity Investments dated 12 January 2004 to Royal & Sun
Alliance Insurance Group plc was received by Royal & Sun Alliance Insurance
Group plc on 13 January 2004, relating to the purchase of ordinary shares of
27.5p each. An extract follows:

________________________________________________________________________

Dear Sirs:

Enclosed are amended notifications of disclosable interests under the U.K.
Companies Act 1985. Please note that while this information details the
disclosable interests of more than one entity, the enclosed disclosure
constitutes separate notifications of interest which have been combined solely
for purposes of clarity and efficiency. It is not intended to indicate that any
of these entities act as a group or in concert with respect to these interests.

These disclosures are made in the interest of conformity with the Companies
Act. The Interest detailed herein was acquired solely for investment purposes.
For disclosure purposes, holdings should be represented as FMR Corp. and its
direct and indirect subsidiaries, and Fidelity International Limited (FIL) and
its direct and indirect subsidiaries, both being non-beneficial holders.

If you have any questions please contact Eleanor Chemlen at (617) 563-1416 or
by FAX at (617) 476-0363.

Kindest regards,

Eleanor Chemlen

Sr. Compliance Specialist

NOTIFICATIONS UNDER SECTIONS 198 TO 202 - U.K. COMPANIES ACT

 1. Company in which shares are held: Royal & Sun Alliance Ins Group
   
2. Notifiable Interest: Ordinary Shares

 A. FMR Corp.
   
82 Devonshire Street

Boston, MA 02109

Parent holding company of Fidelity Management Trust Company (FMTC), a US state
chartered bank which acts as a trustee or investment manager of various pension
and trust accounts. (See Schedule A for listing of Registered Shareholders and
their holdings).

 B. Fidelity International Limited (FIL)
   
P.O. Box HM 670

Hamilton HMCX, Bermuda

Parent holding company for various direct and indirect subsidiaries, including
Fidelity Investment Services Ltd. (FISL) and Fidelity Pension Management (FPM),
investment managers for various non-US investment companies and institutional
clients. (See Schedule A for listing of Registered Shareholders and their
holdings).

3. The notifiable interests also comprise the notifiable interest of:

Mr. Edward C. Johnson 3d

82 Devonshire Street

Boston, MA 02109

Principal shareholder of FMR Corp. and Fidelity International Limited.

4. The notifiable interests include interest held on behalf of authorized unit
trust schemes in the U.K., notwithstanding the exemption from reporting
pursuant to Section 209 (1)(h) of the Companies Act 1985.

 5. These notifications of disclosable interests constitute separate
    notifications of interest in the shares and are combined solely for the
    purposes of clarity and efficiency. Nothing herein should be taken to
    indicate that FMR Corp. and its direct and indirect subsidiaries, Fidelity
    International Limited and its direct and indirect subsidiaries or Mr.
    Edward C. Johnson 3d act as a group or in concert in respect of the
    disclosed interests, or that they are required to submit these
    notifications on a joint basis.
   
 6. The disclosable interests arise under Section 208 (4)(b) of the Act, namely
    where a person, not being the registered holder, is entitled to exercise a
    right conferred by the holding of the shares or to control the exercise of
    such rights, or under Section 203 of the Act respectively.
   
By ___________________________

Eric D. Roiter

Senior V.P. & General Counsel - FMR Co.

Duly authorized under Powers of

Attorney dated December 30, 1997, by

and on behalf of FMR Corp. and

its direct and indirect subsidiaries, and

Fidelity International Limited and its direct

and indirect subsidiaries.

Schedule A

Security: Royal & Sun Alliance Ins Group

                   SHARES HELD MANAGEMENT   NOMINEE/REGISTERED NAME            
                               COMPANY                                         
                                                                               
(Ordinary                8,600 FMTC         Brown Brothers Harriman            
Shares)                                                                        
                                                                               
                    75,419,555 FISL         Clydesdale Bank (Head Office)      
                                            Nominees Limited                   
                                                                               
                     3,396,376 FISL         Chase Nominees Ltd                 
                                                                               
                     1,351,110 FISL         Chase Manhattan Bank London        
                                                                               
                     1,066,792 FPM          Nortrust Nominees Ltd              
                                                                               
                     1,574,700 FPM          Bank of New York Europe            
                                                                               
                       439,700 FPM          Citibank                           
                                                                               
                     5,422,165 FPM          Chase Nominees Ltd                 
                                                                               
                     1,329,700 FPM          Northern Trust                     
                                                                               
                       221,400 FPM          Deutsche Bank                      
                                                                               
                       613,400 FPM          Mellon Nominees Ltd                
                                                                               
                     1,548,600 FPM          HSBC Client Holdings Nominee (UK)  
                                            Limited                            
                                                                               
                   121,736,582 FIL          HSBC Client Holdings Nominee (UK)  
                                            Limited                            
                                                                               
                       593,800 FIL          MSS Nominees Ltd                   
                                                                               
                     2,928,000 FIL          RBS Trust Bank                     
                                                                               
                     2,133,400 FIL          Nortrust Nominees Ltd              
                                                                               
                       426,100 FIL          Bankers Trust                      
                                                                               
                       321,860 FIL          Citibank                           
                                                                               
                    13,895,714 FIL          Bank of New York London            
                                                                               
                     5,433,320 FIL          Northern Trust                     
                                                                               
                    10,745,896 FIL          Chase Nominees Ltd                 
                                                                               
                     3,125,934 FIL          Chase Manhattan Bank London        
                                                                               
                     1,967,780 FIL          Deutsche                           
                                                                               
                       974,800 FIL          State Street Nominees Ltd          
                                                                               
                       995,400 FIL          Bank of New York Brussels          
                                                                               
                       166,200 FIL          State Street Bank & Trust          
                                                                               
                     2,176,649 FIL          JP Morgan                          
                                                                               
Total Ordinary     260,013,533                                                 
Shares                                                                         
                                                                               
Current                  9.03%                                                 
ownership                                                                      
percentage:                                                                    

Change in holdings since last filing: + 25,958,201 ordinary shares

________________________________________________________________________


Name of contact and telephone number for queries

Gill Roberts 020 7569 4032

Name and signature of authorised company official responsible for making this
notification

Jackie Fox, Deputy Group Company Secretary


Date of notification 13 January 2004



END