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AMICE - Association of Mutual Insurers and Insurance Cooperatives in Europe

AMICE

AMICE is the European association representing the mutual and cooperative insurance sector.

Lobbying Activity

AMICE seeks broader EU taxonomy to include insurance mitigation efforts

5 Dec 2025
Topic — The European Commission is reviewing technical screening criteria for the EU environmental taxonomy.
Message — AMICE requests simpler criteria and recognition for climate mitigation and pollution prevention. They suggest including activities that enable transitions, like installing solar panels.123
Why — This would lower compliance costs and improve their low sustainability alignment scores.4
Impact — Low-income households lose out if insurance pricing favors only those who afford adaptation.5
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AMICE Urges EU to Cut Red Tape in Solvency Review

5 Sept 2025
Topic — Consultation on technical updates to prudential rules for the European insurance and reinsurance sector.
Message — AMICE calls for more flexible volatility adjustments and less restrictive investment tests. They also demand reduced reporting obligations and the removal of burdensome supervisory requirements.123
Why — These changes would reduce operational complexity and lower compliance costs for mutual insurers.4
Impact — Market analysts would have access to less granular data if reporting requirements are simplified.5
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Mutual insurers demand tax parity for insurance-based investment products

8 Jul 2025
Topic — The European Commission is developing a blueprint for cross-border retail savings and investment accounts.
Message — The group wants insurance products included as recognized investment accounts with tax benefits. They advocate for product neutrality and the removal of strict lock-in periods.123
Why — This would prevent insurance products from being disadvantaged compared to other financial instruments.45
Impact — Savers and local financing projects lose if standard rules limit investment choices.6
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AMICE urges SFDR revision building on existing disclosure framework

30 May 2025
Topic — The European Commission is reviewing rules to simplify sustainable finance reporting requirements.
Message — AMICE calls for a practical revision that refines key definitions and simplifies disclosures. They suggest rationalising adverse impact indicators and aligning rules with other sustainability laws. New product labels must build on previous efforts rather than discarding existing frameworks.123
Why — This approach protects previous technical investments and reduces costs associated with confusing reporting requirements.45
Impact — External data providers lose revenue if the industry reduces its overreliance on their services.6
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Mutual Insurers Urge EU to Refine Green Reporting Rules

26 Mar 2025
Topic — The consultation concerns amendments to simplify EU Taxonomy sustainability reporting for European companies.
Message — AMICE calls for a reassessment of reporting indicators to reflect insurers' environmental contributions. They request extending simplifications to include minimum safeguards for business partners. They also want to remove requirements that are merely 'nice to have.'123
Why — This approach would reduce administrative costs and improve the sector's competitive position.456
Impact — Public entities would lose access to climate data if data-sharing requirements are removed.7
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Response to Savings and Investments Union

7 Mar 2025

AMICE, the Association of Mutual Insurers and Insurance Cooperatives in Europe, appreciates the opportunity to provide input to the European Commissions call for evidence on the Savings and Investment Union (SIU). We welcome the Commissions initiative to enhance investor participation in financial markets and note with approval the renewed focus on financial competitiveness in the policy agenda. However, we observe that the critical role of insurers and pension funds is insufficiently recognised in the current call for evidence. Given their crucial role in the financial systems and their contribution to increasing the resilience of EU society, it is important that the Commissions agenda includes specific proposals aimed at enhancing their support to the growth of EU companies and financial markets. To this end, we propose a set of targeted proposals designed to both stimulate the retail investor participation in financial markets and sustain the competitiveness of our financial system: - Recognise insurers as key actors in achieving the objectives of the SIU - Acknowledge the importance of insurance-based investment products as a key vehicle for investments in the EU - Re-assess the Retail Investment Strategy in light of the objectives of SIU - Promote Investment in the economy through adjusted prudential requirements - Ensuring fair competition and facilitating market consolidation by aligning the prudential treatment of cross-sectoral participations - Reduce the regulatory overload - Enhance pension savings through mandatory contributions and auto-enrolment - Stimulate long-term investments via targeted tax incentives - Foster financial and insurance education - Enable insurers to invest in productive and innovative firms by removing existing barriers - Boost shareholder democracy as a way to ensure sustainable growth and achieve greater sovereignty - Recognition of social economy entities in the development of the SIU Please find attached our detailed recommendations.
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Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

4 Mar 2025 · Exchange with AMICE on regulatory developments

Meeting with Dirk Gotink (Member of the European Parliament)

11 Dec 2024 · Mutual and cooperative insurers, FIDA

European mutual insurers demand changes to GDPR health data rules

8 Feb 2024
Topic — The Commission is reviewing the General Data Protection Regulation six years after its implementation.
Message — The association requests a legal exception for processing health data in insurance contracts. They also advocate for flexible data rules to support new technologies and innovation.12
Why — This move would resolve legal uncertainties and lower operational costs for insurance providers.34
Impact — Policyholders may lose the absolute right to refuse the sharing of sensitive health information.5
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AMICE demands data reciprocity and sensitive information exclusions

1 Nov 2023
Topic — European policy proposal to expand data sharing and access across financial services.
Message — AMICE recommends excluding health data and proprietary information from the data-sharing mandate. They also advocate for an explicit reciprocity clause with tech giants and an extended implementation timeline.123
Why — This would protect their intellectual property and prevent competition imbalances with tech giants.4
Impact — At-risk policyholders could face much higher premiums if mutual solidarity models are weakened.5
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Response to Review of the Designs Directive

31 Jan 2023

AMICE, the Association of Mutual Insurers and Insurance Cooperatives in Europe, represents a specific sector of the European insurance industry. Our members are characterised by their central focus on their policyholders, who are generally the owners of their insurers rather than the external shareholders. The products, services and benefits derived from our members activities are conceived and applied for the best interests of their policyholders, with a long-term perspective at the core of the relationship between the mutual/cooperative insurer and the policyholder. Mutual/cooperative insurers represent approximately one-third of all insurance business in Europe, and range from some of the smallest insurance entities to some of the largest in the region. AMICE welcomes the opportunity to provide feedback on the European Commissions proposals to recast Directive 98/71 on the legal protection of industrial designs and to amend Regulation 6/2002 on Community designs. AMICE supports the proposed exclusion of spare parts design from legal protection and the introduction of an EU-wide repair clause in Article 19 of the revised Design Directive. This will increase competition and it is essential in the context of increasing car insurance premiums due to the continuous increase in the cost of spare parts. By reusing and recycling spare parts from vehicles that are no longer used or have been involved in car accidents, the proposal will also complement efforts to promote repairs and the circular economy. An EU-wide repair clause will bring benefits to consumers, by increasing consumer choice and lowering prices of automotive spare parts. We believe that the repair clause should apply to both existing and future designs and models registrations. Therefore, we request the deletion of the proposed ten-year transitional period in Article 19(3) of the Directive for spare parts that have already been registered. For further details, please find attached our position paper.
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Response to Open finance framework

2 Aug 2022

While the development of innovative technologies and better access to more data creates opportunities to better serve consumers, it also calls on policymakers to ensure that consumers are even further protected. AMICE welcomes the opportunity to provide feedback to the European Commission’s call for evidence on open finance framework and data sharing in the financial sector. Mutual and cooperative insurers recognise several advantages for consumers from the increased use of digitalisation in the financial sector. Technological advances allow insurers to increase their understanding of consumers’ needs and preferences to provide them with personalized products and innovative services that are better adapted and tailored to their particular circumstances, including better loss prevention advice. AMICE would like to share the attached main considerations which we believe should be taken into account when developing an open finance framework.
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Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

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 policyholders’ best interests. Mutual/cooperative insurers add to the diversity of the European insurance sector, providing competition, financial stability and sustainability, and are represented in all insurer sizes. Legal recognition of the business model varies across Member States: mutual insurers are regulated and formed under national law in different ways, frequently reflecting national distinctions such as social welfare systems. The IRRD proposals create a significant challenge since they address insurers with a “one size fits all” approach, demonstrated with the emphasis on the distinction between shareholders and policyholders/beneficiaries when describing resolution activities. Mutual insurance undertakings have no external owners so there are no shareholders to bear first losses, only policyholders. The IRRD proposals, particularly the resolution tools, are therefore unsuitable for mutual insurers. Resolution objectives focus on protecting policyholders, beneficiaries and claimants; this does not respond to the mutual legal form, and further could create challenges for resolution authorities to respect the legal form, particularly with regard to retaining mutual status. Recent events have demonstrated the insurance industry’s resilience and sustainability in the face of extreme events. EIOPA’s 2021 Stress Test demonstrates this, and its recent report on insurance failures and near misses, built on pre-Solvency II data, identifies factors such as deteriorating capital strength as early identifiers of problems. These factors are now fundamentally addressed in Solvency II which is a robust and powerful regulatory regime. Its inbuilt sturdiness should be assessed rather than an early application of an IRRD regime to further augment regulatory requirements. Where there are concerns about cross-border insurance, these should be addressed separately and tools not be applied wholesale. While we agree that a recovery regime is important, such a scheme should be better aligned with the characteristics of the insurance industry, and not reflective of banking requirements due to the very different nature of the businesses. Insurance has been proven to not have the same risk profile as banks, and should problems arise within an insurer, there is significant time to manage them. The Solvency II ladder of intervention provides clear markers for regulatory intervention aligned with SCR levels, providing clarity and certainty. Proposals under the IRRD allow earlier intervention from resolution authorities bringing uncertainty, and potentially higher capital levels would result, ultimately detrimentally affecting policyholders with no clear commensurate protection. The resolution framework proposals are disproportionate and will not benefit policyholders as intended. They are likely to conflict with national company law and treatments of liquidations and similar instruments. To reflect the national variations in the legal forms, liquidating, winding-up or any other form of termination of a legal entity must therefore be regulated at the same level. These ramifications, along with the challenges for many Member States of establishing the proposed frameworks, will put greater burdens on taxpayers as well as on insurers and policyholders. We propose that the Solvency II structure for insurer recovery is therefore further examined before a new structure is proposed and implemented, and at a minimum that mutual/cooperative insurers with a less critical function in their market are descoped. Resolution proposals should not be applied as they are proposed, and reassessed in the light of the risks posed by the insurance sector.
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Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)

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 specific treatments should be reviewed to enhance the regime in the policyholders’ best interests. Conversely, one should refrain from introducing elements to the current regime that are not needed. In particular, AMICE considers that it is important to upgrade best estimate valuations and market risk calibrations in order to dismantle barriers which do not reflect the long-term business models that best serve their policyholders and the extensive needs of European citizens for long-term protection. Additionally, insurers’ ability to invest in long-term European assets is a growing concern, emphasising the key priority that the changes to Solvency II should represent. Therefore, it is paramount to recognise, facilitate and avoid hindering the ability of insurers to take risks and invest in the economy with long-term strategies that will, in turn, serve the broader European agenda, in particular the Capital Markets Union, the European Green Deal and the European economy’s post-Covid-19 recovery. The risk-based economic approach of Solvency II should better reflect long-term business models in order to more accurately assess the level of possible future losses and avoid artificial volatility in solvency ratios. Excessive conservatism is a threat to the industry as a whole because it leads to prohibitive costs that destroy the benefits that insurance can bring to consumers, society and the economy. In order to better account for long-term business models, one should always be careful not to exercise balance sheet supervision in terms of products or product features only, but out of the wider asset and liability risk management in place. Supervision should primarily be exercised according to and at the granularity of the asset and liability management in place. This is in the best interests of policyholders. The risk management at the heart of insurance is largely based on pooling and diversification across assets and liabilities categories. Thus, in the absence of ring-fencing for specific legal or commercial reasons, the balance sheets of insurance companies are steered and managed on the basis of an overall asset and liability management with a general asset portfolio that do not compartmentalise incoming and outgoing flows by product. Nor do they segregate the regular inflows derived from assets covering own funds. It is important to emphasise that pooling is an optimal cost-efficient mechanism to achieve an economic performance over the long term for both the insurer and the insured. When an overall robust asset and liability management framework is in place which is capable of withstanding adverse scenarios, this eliminates the need to supervise market risks at the product category level. AMICE would like to thank the European Commission for the quality of the work conducted since EIOPA’s final advice roll-out and for the legislative package released on 22 September 2021 aiming at accommodating key issues. Several major concerns of the industry have been taken into account and we are grateful for the care and efforts made to address them. We attach a note where we detail our remaining concerns on unsolved issues that would need to be addressed before continuing with the legislative process.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

AMICE welcomes the opportunity to provide feedback on the draft Delegated Regulation on Article 8 of the EU Taxonomy Regulation. Our comments mainly relate to the provisions concerning disclosures by insurance and reinsurance undertakings. First of all, we welcome the staggered implementation of the delegated act which would give undertakings sufficient time to develop reporting processes. However, we believe that there should be one year delay of implementation (until 2024) for financial market participants (FMPs) as they would need to collect the data disclosed by non-financial undertakings in 2023. The disclosures set out in Article 11(2)(a)-(d) would still require significant implementation efforts. AMICE therefore asks the Commission to consider the cost-benefit of requiring this information a year ahead of the actual KPIs and related qualitative information. We also invite the Commission to ensure better alignment and consistency in EU sustainability reporting requirements, such as between investee companies and FMPs, as well as across different types of FMPs (eg. insurers and asset managers). This would foster comparability of disclosures. KPI for sustainable investment activities We welcome that sovereign entities, other than Taxonomy-aligned sovereign green bonds are excluded from the KPI for sustainable investment activities. We note that as per Article 10 the Commission will review by 1 January 2025 the application of the delegated act and will assess the need for amendments with regard to the inclusion of exposures to central governments and central banks in the numerator and denominator of KPIs for financial undertakings. We appreciate that pursuant to Article 8(3) of the delegated act, the exposures to undertakings not subject to the requirements of the NFRD are excluded from the numerator of KPIs of financial undertakings. Nevertheless, there is an inconsistency between Article 8(3) (and Article 8(5) – which is applicable to all financial undertakings) and template 2 of Annex X which requires to disclose in the breakdown of numerator of the KPI the proportion of exposures to financial and non-financial undertakings not subject to the NFRD, as well as from non-EU countries. The template should be amended in order to properly reflect the requirement under Article 8(3) of the delegated act. In addition, with respect to the KPI related to investments, the draft delegated act requires insurance companies to disclose the coverage of the ratio with reference of the balance sheet total with the exclusion of exposures referred to in Article 8(1) of the delegated act (i.e. sovereign exposures). Template 2 describes the coverage ratio as “The percentage of assets covered by the KPI relative to total investments of insurance or reinsurance undertakings (total AuM). Excluding investments in sovereign entities, other than Taxonomy-aligned sovereign green bonds.” On this point, it would be useful if the delegated act could provide some further clarifications in the text on the denominator of the said coverage ratio (should it include all on-balance sheet exposures with the exception of sovereign exposures?). KPI for sustainable underwriting activities We are worried that the currently proposed KPI will not reflect fairly neither the size of the actual taxonomy-compliant activities of insurance undertakings nor the transition that could be undertaken toward fully compliant activities as regards climate change adaptation. This could result in misinterpretation and misleading conclusions, detrimental - but unjustified - for the sector. The relevant KPI should be: Taxonomy-aligned activities (i.e., underwriting of climate related perils that comply with the technical screening criteria)/taxonomy eligible activities related to the LOBs mentioned in Chapter 10.1 of the Annex II of the Taxonomy climate delegated act and covering climate risks. Please see attached the annex with our full response and detailed comments.
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Response to Social Economy Action Plan

26 Apr 2021

The Association of Mutual Insurers and Insurance Cooperatives in Europe (AMICE) welcomes the opportunity to provide feedback on the roadmap on the European Action Plan for the Social Economy. Mutual and cooperative insurers are key social economy players, especially in the revival of the European economy post-COVID-19. Mutual and cooperative insurance follows the principles of solidarity and sustainability, and is characterised by a democratic governance. As stakeholder-driven companies, they naturally take into account the interest of their member-policyholders in their day-to-day business. In addition, through the participation of their members, mutual societies benefit from a perception of trustworthiness and integrity in the eyes of their customers and the wider society. More than half of all insurance undertakings in the EU are mutual and cooperative insurers which account for a market share of more than 32%. They provide cover for more than 420 million members/policyholders and employ nearly 440,000 people. AMICE strongly supports the European Commission's commitment to present an initiative for a European Action Plan for the Social Economy. In particular, we welcome the Commission’s intention to enhance the visibility and recognition enjoyed by social economy organisations, as well as to provide an ecosystem conducive to the development of the sector. Currently, the treatment of insurance mutuals and cooperatives in Europe can be best described as a “patchwork” of approaches, varying substantially between EU Member States. For some countries the mutual/cooperative insurance sector is well developed and the appropriate legal infrastructure recognising the form is in place within, mainly, business legislation. This is not, however, a widespread approach, and many countries do not legally recognise the legal form of mutual and/or cooperative status. This means, that in some countries, mutual and/or cooperative insurers are treated and regulated in exactly the same way as other market participants, irrespective of size, nature, type of business or types of customers. Therefore, we believe that it is essential to overcome the existing legal barriers faced by social economy undertakings in the EU single market and to provide equal opportunities for all forms of enterprises. As a member of Social Economy Europe, AMICE fully support the proposals and recommendations developed in the attached document.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

AMICE supports the EU efforts to make the European economy greener and more resilient in line with the objectives of the Green Deal and the CMU action plan. We welcome the opportunity to provide comments on the first delegated act under the EU Taxonomy Regulation, in particular the technical screening criteria as identified in relation to Financial and Insurance Activities (“Non-life insurance: underwriting of climate-related perils” (Section 10.1, Annex II)) and Forestry activities (Section 1, Annex I). We support the inclusion of non-life insurance as an eligible activity that substantially contributes to the objective of adaptation of climate change, through the provision of insurance underwriting services related to climate risks, regardless of the activity or the asset insured. We are convinced that climate risk insurance directly reduces the impact of climatic events by partially or totally covering the economic losses resulting from these events. Combined with preventive measures, it helps to reduce future risks. Non-life insurance should therefore be considered to make a substantial contribution to adaptation to climate change, regardless of the sector of activity covered, whether or not this is aligned with the Taxonomy, since the product includes the cover of a climatic risk (NatCat, storm, hail, snow or other climatic hazards linked to weather insurance on harvest). Prevention expenditure undertaken by insurers should also be eligible insofar as they contribute to the objective of mitigating climate change through the reduction of claims, and to the objective of adaptation to climate change on the other hand through the prevention of climate risks. Regarding the technical screening criteria, we believe that some adjustments are needed to appropriately reflect the specificities of our business model. The listed criteria should apply at company level. We suggest removing the sub-criterion linked to price signal in criterion 1 and extending criterion 2 to all prevention or protection measures put in place by the insurer, individually or collectively, regardless if linked to the product or not. Although sharing loss data is key to enhance adaptation to climate change with public authorities or academics, we believe that insurers should be able to anonymise the data they share as such data is business sensitive and it is the intellectual property of the insurer. We strongly question the removal of the activity “Existing forest management” from the delegated act which is a significant deviation from the final recommendations of the TEG published in March 2020. Our detailed comments are included in the attached document.
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Meeting with Mairead McGuinness (Commissioner)

30 Nov 2020 · Pre-Recorded closing address. Insurance regulation, sustainability and risk management.

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Meeting with Valdis Dombrovskis (Executive Vice-President) and

28 May 2020 · COVID-19 relief measures

Response to European Partnership for Safe and Automated Road Transport

27 Aug 2019

AMICE (Association of Mutual and Cooperative Insurers in Europe) welcomes the opportunity to provide feedback on the European Commission’s roadmap on a European partnership for safe and automated road transport. We believe that Option 2 – Institutionalised partnership, pursuant to Article 187 TFEU, as outlined in the inception impact assessment is the most suitable option because of the financial scope and the coordinated approach. Working in an institutionalised partnership will be an efficient way to tackle the fragmentation hurdles identified in the roadmap. The challenges would be best addressed at EU level by means of a common strategic research agenda and coordinated public and private R&I activities. The institutionalised partnership should also enable the participation of the largest spectrum of stakeholders, including the insurance sector. In this regard, AMICE members are willing to assist in discussions related to access to in-vehicle data, as well as to risk management. An institutional partnership will also foster the long-term commitment of all the actors involved.
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Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

AMICE welcomes the opportunity to provide feedback on the European Commission’s Delegated Regulation relating to the implementation of cooperative intelligent transport systems (C-ITS). One of the main challenges that could impede the orderly deployment of connected/automated vehicles and therefore, intelligent transport systems, is the access to in-vehicle data. AMICE considers that a coordinated EU action is necessary in the field of access to in-vehicle data. One of the ongoing risks is to adopt a fragmented and inconsistent approach that could endanger the principle of legal certainty. AMICE understands the need to standardize vehicle-to-vehicle transfer of data and does not challenge the proposal in this respect. But it is clear that both regulatory and private initiatives are multiplying without a consistent view. In addition to this draft Delegated Regulation, there is an ongoing revision of the General Safety Regulation which provides for the mandatory installation of event data recorders on board of new vehicles, thereby leading to further data transfer. According to recital 7 of the proposal, “The introduction of event (accident) data recorders storing a range of crucial vehicle data over a short timeframe before, during and after a triggering event (for example, the deployment of an airbag) is a valuable step in obtaining more accurate, in-depth accident data. Motor-vehicles should therefore be required to be equipped with such recorders.“ In parallel, manufacturers are also already considering transfers of data generated by vehicles they build for their own account, and at this stage without any standardization. This situation is worrisome. A privileged access of only some stakeholders, such as car manufacturers and telecommunications operators, would lead to anti-competitive outcomes and distort competition within the EU single market. This issue should be addressed by adopting a coherent framework on this topic. Therefore, the European Commission should have a global vision and ensure that all service providers can have the same access to that data, communication streams and infrastructure (V2V, V2X, B2G, I2I) in order to be on an equal footing with car manufacturers (or telecommunications operators) in terms of competition. This means direct access free from any interference by vehicle manufacturers (or telecommunications operators), and in accordance with the General Data Protection Regulation. We consider that the data types should be categorized, including a specific category of data of ‘public interest’ which should be standardized. These measures should be taken to ensure a healthy competitive market for vehicle data-based services, to the benefit of consumers.
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Response to Amendments to the implementing rules on solvency applicable to insurers

7 Dec 2018

AMICE welcomes the opportunity to provide comments to the European Commission draft proposals for the changes to the Solvency II Delegated Regulation. We call for changes by the Commission in six areas (see detail in the document attached)
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Response to Cooperative, Connected and Automated Mobility (CCAM)

16 Nov 2018

AMICE welcomes the opportunity to provide feedback on the European Commission’s roadmap on Cooperative, Connected and Automated Mobility (CCAM). One of the main challenges that could impede the deployment of connected and automated vehicles is the access to in-vehicle data. AMICE welcomes the Commission’s intention to provide further guidance on a governance framework for access to and sharing of data generated by connected vehicles. The Commission rightly points out that “centralisation of in-vehicle data as currently implemented by some market players, might in itself not be sufficient to ensure fair and undistorted competition between service providers.”. The deployment of connected and automated driving suffers from highly fragmented regulatory approaches in different markets. Therefore, a coordinated EU action is necessary in the field of in-vehicle access to data given that the unfair advantage of vehicle manufacturers have over other stakeholders. The European Commission should ensure that all service providers can have the same access to this data and be on an equal footing with car manufacturers in terms of competition. This means access free from any interference by vehicle manufacturers, and solely based on the consent of drivers/consumers. These measures should be taken to ensure a healthy competitive market for vehicle data-based services, to the benefit of consumers. On the access to vehicle data, AMICE invites the European Commission to consider the following points:  As long as a neutral data access device could not be agreed with all the manufacturers, access via OBD (On-Board Diagnostic) interface must be preserved.  When there is access to data, it must include all the vehicle data produced by the systems installed in the vehicle by the manufacturers, whether these data are raw or aggregated.  Although ensuring that the transfer of in-vehicle data is secure is essential, cybersecurity considerations which are unsubstantiated should not represent an impediment to such access. On the driver's consent for the transmission of data, AMICE is of the view that:  Consent must only be necessary outside the context of the accident. Making the consent mandatory in this latter circumstance would eventually make it a condition of subscription or even undesirable guarantee.  In the event of an accident, if the driver has not formally agreed to the transmission of the data, this should not prevent the establishment of his/her liability. AMICE also urges the European Commission to take into consideration the conclusions of the 2017 TRL study on access to in-vehicle data and resources, which provides a good overview of the various technologies available for such access. Finally, AMICE notes that in its roadmap the European Commission is only focusing on three issues: data access, cybersecurity and connectivity. In addition, AMICE invites the European Commission to consider civil liability aspects resulting from autonomous driving. As highlighted in the recent motion for a European Parliament resolution on autonomous driving in European transport (2018/2089(INI)), the European Parliament draws the Commission attention to the fact that this civil liability aspects have to be settled under a European basis, not national ones and urges the Commission to take position. About AMICE (Association of Mutual and Cooperative Insurers in Europe) AMICE is the voice of the mutual and cooperative insurance sector in Europe. The Brussels-based association advocates for appropriate and fair treatment of all mutual and cooperatives insurers in a European Single Market. It also encourages the creation and development of innovative solutions for the benefit of European citizens and society. Mutual and cooperative insurers have a market share of more than 30% of the European insurance sector, with more than €420 billion in premiums written and over 410 million policyholders across Europe.
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Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

AMICE welcomes the opportunity to provide feedback on the European Commission’s proposal to amend the Motor Insurance Directive. Please see the attachment with our comments.
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Meeting with Tatyana Panova (Cabinet of Vice-President Valdis Dombrovskis)

5 Dec 2017 · Insurance related issues

Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

19 Jan 2016 · Solvency II, Insurance Distribution Directive, Call for evidence, Green paper on Retail banking