Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

Comments on the Solvency II Review Directive (SIIRD) and the Insurance Recovery and Resolution Directive (IRRD) In summary the European Commission's proposals for a SIIRD and for the IRRD are welcomed, however the European Commission missed the oportunity to propose a framework for harmonised insurance guarantee schemes (IGS), which is regrettable and not in line with the interests of European citizins.

Mutual/cooperative insurers are responsible for approximately one-third of all insurance business in Europe. They are characterised by a central focus on their policyholders, who are generally their owners rather than external investors. Any benefits from the running of the organisation are for policyholders’ best interests.

Insurance Ireland (II) appreciates the opportunity to provide its feedback on the European Commission’s (EC) proposal establishing a framework for the recovery and resolution of (re)insurance undertakings (hereafter: IRRD). II notes that the EC presented IRRD, but did not present a proposal for the harmonisation of Insurance Guarantee Schemes (IGS).

Folksam, Länsförsäkringar and Skandia’s response on the consultation on EC proposals on establishment of rules for (re)insurers on recovery and resolution We, Folksam Mutual life insurance and Folksam mutual non-life insurance (“Folksam”), Länsförsäkringar and Skandia Mutual Life Insurance Co. (“Skandia”), hereby comment on the proposed Insurance Recovery and Resolution Directive (IRRD).

The German insurance industry supports the objections of strengthening policyholder and consumer protection and financial stability. We also take a positive view of the intended harmonization of resolution tools and the improvement of coordination and cooperation between the competent authorities in the various Member States.

Please see feedback in the attached file. Summary Länsförsäkringar sincerely appreciate this opportunity to provide reflections and comments regarding this very important topic. As members of Insurance Sweden, we fully share the views expressed in their response on the European Commission’s (EC) proposal of a framework for the recovery and resolution of insurance and reinsurance undertakings.

The European Commission has adopted EIOPA’s proposal to harmonise recovery & resolution requirements. The proposal introduces pre-emptive recovery and resolution planning requirements. It is noted that some of the proposed resolution tools and powers are already present in the Belgian Solvency II law and are generally supported.

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal on establishment of an Insurance Recovery and Resolution Directive. Please find below our general comments. The detailed Insurance Europe comments can be found in attachment.

The PRI welcomes the review’s focus on addressing long-term sustainability risks in the insurance sector. However, more ambitious measures will be needed to align financial flows with the EU’s new sustainability objectives. ■ The reform’s aim to strengthen insurers' management of climate risks is particularly welcome.

Zurich welcomes the proposed amendments to the Solvency II Directive, as well as the outlined revisions to the Delegated Acts. We are pleased with the targeted improvements of the Commission to the initial EIOPA advice, which result in a more balanced outcome and look forward to understanding the full implications of the Solvency II review when the proposed changes to the Delegated Acts are released.

Insurance Sweden welcome this opportunity to comment on the proposed Insurance Recovery and Resolution Directive (IRRD). As a member of Insurance Europe, we share the views expressed in their response on the European Commission’s (EC) proposal of IRRD.

Länsförsäkringar, Sweden (Full feedback is found in the attached file) Summary We sincerely appreciate this opportunity to provide reflections and comments regarding the amendments in Solvency II. We wish to specifically mention some parts of the proposal for amendments in the Solvency II directive that we find worrying and problematic.

We believe it is necessary to reiterate that there is a pressing need to take the opportunity of the current Solvency II 2020 Review to optimise the regime. We regard Solvency II as a robust regime which has proven its strength since its implementation in 2016. However, we believe that certain specific treatments should be reviewed to enhance the regime in the policyholders’ best interests.

In brief: On 22/09/2021 the European Commission published a draft amendment to the Solvency 2 Directive, which will then be submitted to the European Parliament and the Council of the European Union. At the same time, the Commission must define level 2 measures (delegated regulation) to clarify numerical provisions.

Filed in French · English published by the European Commission

Please see attached ClientEarth's full submission in response to the European Commission's proposal for the review of Solvency II. As set out more fully in our attached submission, ClientEarth welcomes that the Commission is introducing enhanced rules on climate change scenario analysis, in its proposal for amendments to Solvency II (the “Proposal”).

ShareAction welcomes the Commission’s efforts to integrate sustainability considerations in the review of the legislative framework for European (re)insurers, Solvency II. However, more ambitious regulatory changes are needed to allow the European insurance sector to face mounting sustainability risks and play a positive role in the transition to a greener economy, in view of achieving the EU’s sustainability…

ANIA appreciates the EC’s recognition of some important critical issues highlighted by the Insurance Industry in the stakeholder consultation, such as those related to the design and calibration of the Volatility Adjustment.

ACA believes that the European Commission (EC) proposals regarding the supervision of ‘significant’ cross border activity are too simplistic, not risk-based and therefore inappropriate. These proposals go beyond the mandate of enhancing supervisory cooperation and essentially introduce a new level of supervision in relation to: 1.

The European Commission has good intentions to make improvements to the Solvency II framework. For this purpose, it has proposed changes to the Solvency II directive and proposed a new directive with recovery and resolution measures. The proposals are heading in the right direction, but technical specifications still need to be further developed in the Delegated Regulation of Solvency II.

The German insurance industry supports the Solvency II review and welcomes many aspects of the European Commission’s proposals. We are convinced that the risk-based Solvency II regulation already ensures a very high level of policyholder protection and contributes significantly to financial stability. Recently, it proved its worth in the challenges of the Covid-19 pandemic.

FERMA, the Federation of European Risk Management Associations is happy to provide feedback on the European Commission's proposed amendments to Solvency II, specifically concerning proportionality. As the representative body for almost 5,000 risk and insurance managers at European level, we take great interest in the prudential rules governing insurance undertakings.

Listed real estate companies have continuously yielded stable and strong long-term performance to investors, especially insurers and pension funds through reliable dividends, effectively contributing to the retirement of millions of people.

Insurance Europe welcomes the opportunity to provide feedback on the EC’s proposal for a Directive amending Solvency II. Please find below the key industry messages. The detailed Insurance Europe comments can be found in attachment.

The Insurance Europe Reinsurance Advisory Board (RAB) welcomes the opportunity to contribute to the European Commission’s consultation on the proposal for an Insurance Recovery and Resolution Directive (IRRD). The Commission’s proposals in areas such as recovery and resolution allow for what the RAB strongly believes would be an unjustified and significant increase in regulatory requirements and operational and…

The Insurance Europe Reinsurance Advisory Board (RAB) welcomes the opportunity to contribute to the European Commission’s consultation on the Solvency II review proposal. The RAB strongly supports the Solvency II regime and its risk-based approach. Solvency II is today the most advanced insurance regulatory regime in the world and it has passed the test of the COVID-19 crisis.

As a member of Insurance Europe, Insurance Sweden overall share the views expressed in its response to the European Commission’s (EC) proposed amendents in the current review of the Solvency II Directive. However, in the attached document we wish to highlight and elaborate further on the proposal to widen the corridor for the symmetric adjustment to the equity risk charge by amending Article 106 (3).

From the AAE’s point of view, Solvency II has proved to be a well-functioning risk-based framework which is suitable to ensure policyholder protection and financial stability in Europe. Nevertheless, the experience of 5 years of application and especially the low interest rate environment, the COVID-19 pandemic and the progressing climate change revealed the need to reassess the current framework.

Insurance Ireland (II) appreciates the opportunity to provide its feedback on the European Commission’s (EC) proposal to review the Solvency II Directive (hereafter: the Review) and its Communication on its plans to review the Delegated Regulation on Solvency II, (EU) 2015/35.

The proposals for a review of the insurance sector’s prudential regulation feature a major inconsistency with respect to addressing the systemic risk dimension. On the one hand, they recognise the systemic nature of the sector by introducing, in a most welcome move, a directive establishing a framework for the recovery and resolution for insurance and reinsurance companies.

Solvency II is a complex supervisory regime for the EU (for an introduction see e. g. Gründl/Kraft 2019 or Van Hulle 2019), which is blueprint also for supervisory systems in other countries all over the world. The Solvency II project discussions resulting in the introduction of the framework of Sol-vency II in 2016 initiated rethinking insurance regulation and supervision, globally.

Generali Group believes that the Solvency II (SII) framework has made a positive contribution to aligning capital with the risks incurred by the industry and in strengthening governance models and risk management processes. The framework is now well established and it has contributed to the stability of the insurance industry.

We welcome the EC Inception Impact Assessment and agree to a significant extent with its objectives and policy options. However, there are some key omissions and some refinements that are necessary to ensure the right outcomes Solvency II (SII) is strongly supported but is excessively conservative and has some measurement flaws and excessive operational burdens that create unnecessary costs and barriers, in…

Finland / Ministry of Social Affairs and Health thanks for the opportunity to comment on and mainly agrees with the Inception Impact Assessment. Yet, some topics merit a comment. A. Context, problem definition and subsidiarity check Finland notes that under the risk-based Solvency II framework it is a (re)insurer’s primary duty to maintain its own solvency in order to protect the policyholders’ and beneficiaries’…

Insurance Ireland is the representative body of the Irish insurance industry. Ireland is the 5th biggest insurance market in the EU and the 2nd biggest market for reinsurance. Our members serve customers in more than 110 countries including 24 EU Member States. The further integration of the EU single market is the key objective of our vision of an integrated, innovative and sustainable EU single market.

Summary The German insurance industry supports the modern, risk-based SII regime and believes it works well overall. Its level of security is very high. Particularly in the Covid-19 crisis, SII has proven its worth. Nevertheless, the SII review should be used for some important improvements. Regulations that are overshooting from a risk perspective should be corrected in all three pillars.

The Insurance Europe Reinsurance Advisory Board (RAB) strongly supports the Solvency II framework and its underlying risk-based, market consistent approach. The RAB’s view is that the current Solvency II framework broadly works as intended. However, the Solvency II review needs to strike the right balance between stability and prudence on the one hand and efficiency and growth on the other.

UNESPA (Spanish Association of Insurers and Reinsurers) appreciates the opportunity to comment on the European Commission Inception Impact Assessment on the 2020 Review of Solvency II. UNESPA is the representative body of 195 private insurers and reinsurers that stand for approximately the 96% of the Spanish insurance market.

INREV is pleased to have the opportunity to make a few brief comments on the Inception Impact Assessment ‘Roadmap’. We strongly supports the Commission’s decision to undertake a broad scope of review that goes beyond the required Solvency II review topics.

I am writing on behalf of the Irish Department of Finance. I want to thank the Commission for the opportunity to provide feedback on its inception impact assessment regarding the Solvency II Review. It is our intention to provide a more detailed response to the public consultation in advance of the October deadline.