Compare organizations

We appreciate the opportunity to comment on the call for evidence. While we consider targeted modifications of existing legislation to be appropriate in some points, we are convinced that the current regulation on insurance-based investment products has, for the most part, worked well in practice.

Ireland is a global hub for (re)insurers, captives and insurtechs. Irish insurers service customers across the EU, making Ireland the fourth largest insurance market in the EU and no.1 exporter of life and non-life insurance. Irelands life insurers have an outstanding expertise in providing high-quality services to their customers and allowing them to participate in capital markets.

Insurance Ireland welcomes the FiDA proposal. However, we outline some considerations: Scope.We suggest a phased approach by line of business with pre-defined timelines, starting with motor and home insurance Art.4 requires further clarity especially whether the customer should have the right to access this data themselves, automate such data access with software, or authorize a FISP to access the data on their…

The German insurance industry generally supports the European considerations to promote a data-driven financial system. With the presented legislative proposal on a framework for access to financial data ("FiDA"), retail and corporate customers are to be given more creative scope in the use of their financial data.

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.

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 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.

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).

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.