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

Banking and financial services

The Commission will carry out a review of some elements of the Solvency II Directive (2009/138/EC). The Directive lists several issues that must be reviewed, such as long-term guarantee measures, the solvency capital requirement, or the minimum capital requirement. Given the experience acquired with the application of Solvency II, it is now time to assess whether some of its measures remain fit for purpose. The Commission will also assess the opportunity to include other elements in the review.

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Public consultation

ID: 12461

Lobbying Activity

31 responses

Consultation response

Insurance Europe, 13 Jan 2022

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 EC’s proposals to implement a…

Consultation response

Insurance Europe, 12 Jan 2022

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. Solvency II (SII) has provided many of its intended benefits,…

Consultation response

Insurance Europe, 26 Aug 2020

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…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 13 Jan 2022

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…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 12 Jan 2022

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…

Consultation response

Gesamtverband der Deutschen Versicherungswirtschaft e.V., 26 Aug 2020

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.…

Consultation response

Finance Watch, 10 Jan 2022

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…

Consultation response

Assicurazioni Generali S.p.A, 26 Aug 2020

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…

Consultation response

Insurance Ireland, 13 Jan 2022

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…

Insurance Ireland urges Solvency II reforms to boost competitiveness

Insurance Ireland, 11 Jan 2022

The organization requests including competitiveness in Solvency II objectives, removing single market barriers, and ensuring proportionate application without stigmatizing cross-border business. They want refined group supervision and reduced reporting burden, plus technical adjustments to risk margin and calibration parameters.
This would reduce regulatory burden and enhance their global competitiveness as insurers.

Irish insurers urge lower capital requirements to boost EU growth

Insurance Ireland, 26 Aug 2020

The group calls for reduced capital requirements and harmonized EU-wide supervision. They claim existing risk margin calculations are excessive and discourage long-term investment.
Reduced capital needs would unlock funds for growth and enhance global competitiveness.
National authorities lose power if regulatory application is no longer left to discretion.

Consultation response

Zurich Insurance Company Ltd, 13 Jan 2022

Please see attached file.

Consultation response

Fairshare Educational Foundation (ShareAction), 12 Jan 2022

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…

Consultation response

Associazione Nazionale fra le Imprese Assicuratrici, 12 Jan 2022

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. These changes somewhat contribute to reflect, in aggregate, the reality of…

Consultation response

Principles for Responsible Investment, 13 Jan 2022

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…

Consultation response

Hospodářská komora České republiky, 13 Jan 2022

Naše připomínky zasíláme v příloze.

Consultation response

Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg, 12 Jan 2022

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…

Consultation response

Federation of European Risk Management Associations, 12 Jan 2022

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…

Consultation response

UNIÓN ESPAÑOLA DE ENTIDADES ASEGURADORAS Y REASEGURADORAS, 25 Aug 2020

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…

Consultation response

Svensk Försäkring, 13 Jan 2022

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. In the attached response we highlight and…

Consultation response

Svensk Försäkring, 12 Jan 2022

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…

Consultation response

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 13 Jan 2022

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…

Consultation response

AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe, 12 Jan 2022

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…

Consultation response

Actuarial Association of Europe, 12 Jan 2022

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…

Consultation response

Assuralia, beroepsvereniging van verzekeringsondernemingen, 13 Jan 2022

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…

Consultation response

Assuralia, beroepsvereniging van verzekeringsondernemingen, 12 Jan 2022

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…

Consultation response

Reinsurance Advisory Board, 12 Jan 2022

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…

Consultation response

Reinsurance Advisory Board, 12 Jan 2022

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…

Consultation response

Reinsurance Advisory Board, 25 Aug 2020

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…

Consultation response

Fédération Nationale de la Mutualité Française, 12 Jan 2022

Summary 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…

Consultation response

, 25 Aug 2020

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. While we fully support Solvency II’s…