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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.

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 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.

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…

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.

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…

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.

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.

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).

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.