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The Call for Evidence does not provide sufficient detail on the magnitude of the problems identified or the concrete proposals under consideration. Respondents are asked to consider the impact of policy initiatives, but the initiatives and policy direction under consideration are unclear, making it difficult to provide meaningful feedback.

I. Digital communication support The Czech Insurtech Association would like to express support for the European Commission's proposal regarding the prioritization of digital communication with customers within the framework of the Retail Investment Package.

Insurance Europe supports the goal of the Retail Investment Strategy (RIS) to increase retail participation in financial markets, while protecting investors from unfair practices. Within a well-designed legislative framework, insurance-based investment products (IBIPs) are key to enabling consumers to invest with confidence in capital markets, access insurance protection and prepare for old age.

Open finance, if designed with the right framework, has the potential to positively impact both consumers and insurers. However, it is important to get the framework right, so that the potential can truly be achieved. This raises important considerations in relation to consent management, the scope of the data sharing and ensuring a level playing field among market participants.

I. General support to the initiative On behalf of the Czech Insurtech Association, we would like to express our strong support for the proposed Open Finance Framework (FIDA) and, specifically, the development of an Open Insurance Framework.

The Czech Insurtech Association would like to express its gratitude for the new and modern law on liability for defective products, and is excited about the prospect of it soon becoming a reality. We are very supportive in creating a level playing field for EU operators and those non-EU based, and we welcome the introduction of clear and predictable rules facilitating legal certainty and predictability of the…

Insurance Europe appreciates the European Commissions intention to create a liability regime suitable for the digital age by revising the Product Liability Directive (PLD). However, the proposal, as currently drafted, would negatively impact the availability of insurance and would therefore not meet its intended purpose of enhancing consumer protection while encouraging innovation.