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Association des compagnies d’assurances et de réassurances du Grand-Duché de Luxembourg

ACA

It is the mission of ACA to promote the interests of the Luxembourg Insurance sector and update members on developments taking place at the EU level.

Lobbying Activity

Meeting with Marc Angel (Member of the European Parliament) and FEDIL - The Voice of Luxembourg's Industry and

3 Dec 2025 · Competitiveness

Meeting with Gilles Boyer (Member of the European Parliament) and Association des Banques et Banquiers, Luxembourg and Association Luxembourgeoise des Fonds d'Investissement

14 Nov 2025 · SIU, Pension package, Savings and Investment Accounts, Market integration package

Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and

23 Oct 2025 · Discussion on simplification and the Savings and Investments Union

Meeting with Alexandra Jour-Schroeder (Deputy Director-General Financial Stability, Financial Services and Capital Markets Union) and Association des Banques et Banquiers, Luxembourg and Association Luxembourgeoise des Fonds d'Investissement

19 Sept 2025 · Financial sector’s priorities

Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

21 Jul 2025

ALFI response to the questions of the EU Commission Call for Evidence on Supplementary Pensions. First pillar A critical step toward modernising Europes retirement landscape is more transparency to citizens as to what they can expect to receive from the first pillar so that they can better plan for retirement. EU member states should be required to provide their citizens with better information on provisional first pillar pension monthly pay-outs. Such reporting would need to be based on clear and transparent calculation rules (defined at EU level) incorporating the evolution of demography and the provisional workers/pensioners ratios, retirement age, etc. and should be a realistic picture of what citizens can reasonably expect at the time of their retirement. This reporting would also create a strong incentive for them to revert to second and third pillar solutions to save for their retirement. Occupational Pension - Second Pillar The EU does not have an efficient pan-European framework for second pillar pensions. A pan-European framework could contribute to foster a more harmonized fit for purpose regime in line with the concept of a single internal market. To ensure the efficiency, transparency and in order to increase participation of second pillar schemes, the following elements should be taken into consideration: How to foster competition: second pillar solutions should be able to be provided at a level playing field by banks, insurance companies and investment funds / asset managers; How to limit the use of capital guaranteed products in line with the risk return profiles of the beneficiaries; How to assist beneficiaries in their product choices via guidance, advice or model portfolios; How to ensure full transparency of scheme costs and ensure easy transferability of schemes between providers/employers without having to exit; How to best structure default options with a long-term perspective (i.e. adjusting the risk profile of the portfolio according to the age of the investor and the corresponding cash flow needs); How to encourage more investments in the real economy. Despite the IORP Directive dating back to 2003 and its revision in 2016, cross-border IORPs remain largely ineffective. In our response to the consultation, we will examine these barriers in depth and explore potential solutions to overcome them. Auto Enrolment We consider auto-enrolment a powerful tool to improve coverage in occupational pensions. Since auto-enrolment in occupational pensions has proven highly effective in increasing participation, the EU should play an active role in identifying the key features for successful auto-enrolment schemes and provide guidance to Member States. We recommend to consider the following elements: - How to best structure default options (for example using life-cycle investment strategies) - How to reach maximum participation through auto-enrolment mechanisms and attractive tax incentives - How to discourage opt-outs and early withdrawals Personal Pension - Third Pillar (PEPP) We welcome a review of the PEPP framework with a view to simplify it and to address known roadblocks. This section will be further developed in our upcoming response to the consultation. Prudent person We will further develop the prudent person principle in our consultation response, with a detailed focus on investments into equity but also alternative asset classes, whilst referring to principles of suitability, risk management and diversification.
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Response to Recommendation on savings and investment accounts

7 Jul 2025

ALFI welcomes the opportunity to respond to call for Evidence on Savings and Investment Accounts (SIA). 1. Possibility to access a wide range of products: SIA should be accessible via banks, insurers, fund managers, and investment firms, functioning like standard investment accounts. Access should not be limited to bank accounts, any format (e.g. securities accounts, insurance wrappers, blockchain-based accounts) should qualify to encourage fair competition. They should also be available to minors, promoting early financial literacy. Parents should benefit from tax deductions on annual contributions to minors' accounts (if fully invested), with no geographic restrictions. (Grand)parents often open savings accounts. SIA can optimise returns and be educational. With parental control, minors should be allowed to invest from a certain age to build financial understanding. There should be no mandatory EU/national asset allocation as there is a natural home bias. No lock up periods and no fee caps. The SIA is a ready-to-implement model requiring no new agencies or approvals. Eligibility criteria should be market-driven (no approval requirement) and existing ex-post controls should be used. 2. Eligibility of products: The EU already offers a wide range of products (UCITS, ELTIFs, AIFs, etc.) suitable for SIAs. These should benefit from uniform, simple, non-discriminatory tax treatment, deductible contributions and tax-free growth. 3. Easy access: SIAs should be fully digital, with streamlined KYC to allow fast, secure setup. The user experience must be intuitive, mobile-friendly, and aligned with digital-native expectations, ensuring simplicity, transparency, and trust. Providers should handle tax reporting and apply relevant exemptions, including for cross-border workers. Parental oversight for minors accounts must be clearly defined and robust to ensure proper supervision. 4. Easy and affordable portability of the account to other providers: To ensure mobility, transfers between providers should be possible. While full cross-border portability remains complex due to tax differences, savers should be able to transfer their existing investment products or retain access to the same investment products as they move across Member States. 5. Pre-conditions and limitations: There should be no discrimination or restrictions on the free movement of capital based on the geographic location of EU assets. Cross-border access and transfers of SIAs should be as smooth and straightforward as local ones, especially for cross-border workers. The Commission can only promote best practises/ or best in class models in relation to tax treatment. A clear, cost-transparent framework for transferring accounts between providers (including in different Member States) is essential to reduce complexity and support mobility in particular for cross border workers. 6. Tax simplification and advantages: Given the diversity of national tax systems, a single EU-wide tax model for SIAs is unlikely. Instead, SIAs should align with national frameworks, offering preferential tax incentives tailored to each Member State, especially to encourage retail investor participation in EU-based products. Tax benefits may include income tax reductions, exemptions on dividends, capital gains, or inheritance. Tax regimes should avoid defining min. holding periods in order to ensure maximum participation. Eligible products should include equivalent offerings from all Member States, ensuring non-discrimination and investor choice. Simplified tax compliance is essential, retail investors should not face heavy administrative burdens. Efficient withholding tax relief mechanisms must also function properly to enhance returns and attractiveness. 7. Any other incentives/encouragement: Financial and tax literacy should be promoted to help retail investors understand the risks and benefits of long-term investing through SIAs. EU/national promotional & educational campaigns needed.
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Meeting with Maria Luís Albuquerque (Commissioner) and

18 Jun 2025 · Working lunch with financial associations on the Savings and Investments Union

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

4 Jun 2025

ACA is the Association des Compagnies dAssurances et de Réassurances du Grand-Duché de Luxembourg, the Luxembourg Insurance and Reinsurance Association. As such ACA will not address the issues on market-infrastructures and asset managers as insurers and reinsurers are more indirectly impacted. The association would nevertheless like to answer the points regarding markets barriers and supervision as the issues are similar to discussions that have been raised in the context of insurance in the past. Regarding market barriers, Luxembourg insurers are facing similar issues. Freedom of services in the area of insurance does work and has done so in the past. What Luxembourg insurers have nevertheless noticed, is that Member States have started erecting on purpose or not barriers in recent years. These relate e.g. to double reporting for AML or tax purposes. There is also an example of a Member State preventing the distribution of capitalization products linked to investment funds provided for by the Solvency directive. ACA will give more detailed input via the new and dedicated channel on barriers in the internal market for financial services. ACA does not believe that more EU level supervision including giving EIOPA direct supervisory powers would solve the above-mentioned barriers originating in national provisions on AML or tax, or national legislation. Therefore the benefits of more EU level supervision seem rather intangible. The downsides are nevertheless rather clear: Experience from the SSM shows that the hub and spoke model has not led to simplification. On the contrary, the result has been increased complexity via the introduction of an additional level of supervision, additional requirements and a significant increase of supervisory fees as well on the level of the National Supervisory Authorities (NSAs) as on the level of the ECB. Therefore, for insurance as well, introducing an additional layer of EU-level supervision would not automatically simplify rules or lighten administrative burdens; if anything, it could create extra tiers of oversight, duplication, and complexity. A single centralized supervisor would in theory bypass the issue of multiple layers. In practice it would nevertheless mean a supervisor in an ivory tower in Frankfurt far away from market realities on the ground and remote from national specificities and local legal frameworks on which insurance products are based. As consequence EIOPA would have to rely again on NSAs or open its own national structures. That would mean back to square one: the costs and complexities of a multi layered system. The emphasis should instead be on smarter supervisionstepping up coordination, streamlining data-sharing, and adopting more proportionate, risk-based approaches. Convergence can be fostered through closer cooperation and clearer guidance, without expanding EU-level supervisory footprints or reporting requirements. In short, EIOPA and ESMA for that matter already have powerful convergence tools that might need to be fully used. ACA favors retaining primary oversight at the national level and encourages National Supervisory Authorities (NSAs) and EIOPA to keep leveraging the tools already available to promote supervisory convergence, while preserving the flexibilities that current regulations allow. Expanding EU-level supervision would bring costs and risks that outweigh any likely benefits.
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Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union) and Association des Banques et Banquiers, Luxembourg and Association Luxembourgeoise des Fonds d'Investissement

22 May 2025 · Exchange of views on topics related to Savings and Investment Union, Internal Market and simplification.

Response to Savings and Investments Union

7 Mar 2025

The Call for Evidence as well as various other documents among others the Commission work programme for 2025, the Competitiveness Compass as well as the Letta and Draghi report stress the need to channel citizens savings from currents and savings accounts into financial markets. Insurers have a key role to play in particular via Insurance Based Investment Products (IBIPs) that can in addition offer protection elements like guarantees or risk cover. For citizens to move from bank deposits to investments like IBIPs, significant efforts need to be done to improve often lacking basic financial literacy in the various Member States. To cover future generations as a whole and give equal chances to all, there is no way around including financial literacy in school curricula as a recurring topic at various stages of their school career. Pensions are a potent way of productive savings. While the first pillar is already well established, it faces its own challenges. It is crucial for citizens to be aware of what pension they can expect from the first pillar via what could be called a pension dashboard. An example can be the www.mypension.be website in Belgium. Citizens in all Member States should know from their first day of employment what pension they can reasonably expect so that they can start investing early on and be able to take advantage of the compounding effect. The second pension pillar has significant potential for channeling retail savings into the economy, including via insurance products. The key here is the principle of autoenrollment where employees automatically contribute a percentage of their salary into a second pilar pension product which already nowadays is often an insurance product. Tax advantages granted by Member States are key here to encourage both employers and employees to increase savings and investments. The third pension pilar is complementary to the above. Here IBIPS and insurance-based pension products can play a key role. Simple and once and for all tax advantages are crucial to entice citizens to save for old age. Experience has shown that tax deferrals are not successful means to lead to mass adoption. When putting the groundwork for boosting retail investment including through IBIPs, it is important not to lose citizens and retail investors because of a complex and frightening investor journey. This is unfortunately the case with the Retail Investment Strategy (RIS) that is currently on the table. Competitiveness and simplification are key and need to be applied not only to RIS but also FiDA as well as Solvency II L2. In the context of the SIU, the concept of centralized EU supervision is regularly brought up. ACA does not see any material merit in centralization of that kind. The precedent of the SSM on the banking side has shown that it entails mostly an additional layer of supervision on top of the existing NCAs which creates additional costs for the industry with very limited benefits. Convergence of supervision and exchanges of information rather than a centralized supervisor are the way forward. The Call for Evidence as well as various other documents among others the Commission work programme for 2025, the Competitiveness Compass as well as the Letta and Draghi report stress the need to channel citizens savings from currents and savings accounts into financial markets. Insurers have a key role to play in particular via Insurance Based Investment Products (IBIPs) that can in addition offer protection elements like guarantees or risk cover. For citizens to move from bank deposits to investments like IBIPs, significant efforts need to be done to improve often lacking basic financial literacy in the various Member States. To cover future generations as a whole and give equal chances to all, there is no way around including financial literacy in school curricula as a recurring topic at various stages of their school career. Pensions are a potent way of productive savings. While the first p
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Meeting with Pawel Wisniewski (Cabinet of Commissioner Christophe Hansen) and Association des Banques et Banquiers, Luxembourg and Association Luxembourgeoise des Fonds d'Investissement

25 Feb 2025 · Role of the financial sector in financing agriculture and rural areas

Meeting with Ugo Bassi (Director Financial Stability, Financial Services and Capital Markets Union)

11 Feb 2025 · Exchange of views on Internal Market

Meeting with Marc Angel (Member of the European Parliament) and FEDIL - The Voice of Luxembourg's Industry and

18 Dec 2024 · ECON and IMCO-related issues

Meeting with Marc Angel (Member of the European Parliament) and Association des Banques et Banquiers, Luxembourg and Association Luxembourgeoise des Fonds d'Investissement

9 Jan 2024 · ECON-related issues

Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

26 Jun 2023 · Freedom to provide insurance services, retail investment strategy, solvency II

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

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 of supervision in relation to: 1. Information to be exchanged between home and host supervisors, some of which goes beyond the requirements and objectives of the Solvency II prudential framework; 2. Direct control for the host supervisor and EIOPA, which would undermine the home country control principle. The threshold of 5% GWP generated in a given member state, as a trigger for identification of significant cross border business is too simplistic. This measure essentially is used to ‘catch all’ cross border business under scope of the new requirements, which will place a large burden on supervisory authorities and possibly undermine the intended objective of enhanced supervisory cooperation. ACA fully supports enhanced supervisory cooperation as a way of protecting consumers. The Solvency II changes to cross border supervision should not however result in discriminating against (re)insurers and Member States' markets whose business model is complemented by the opportunities given by the single market and the nature of the risks they underwrite. ACA members continue to discuss possible alternatives to the 5% threshold, to achieve a more targeted result. For example, basing the analysis on the percentage of the local market activity which the cross border business represents etc. ACA believes that enhanced supervisory cooperation should not compromise the home member state principle. We understand the increasing focus on consumer protection related issues and the Luxembourg industry fully supports that policyholders shall have the possibility to choose from fair, competitive and safe products. It is important however to note that many cases identified as being problematic in the cross-border sense, arise from situations of illegal or fraudulent activity, which do not fall under scope of the Solvency II prudential regime. The objective therefore should be to assist national supervisors and law enforcement agencies to tackle fraud and bring those responsible to justice. Diluting the home country control principle could have a very disruptive effect, by slowing down or even preventing swift and effective intervention. We do not agree with the EC proposal to allow host supervisors and EIOPA to address supervisory requests directly to (re)insurers. All information requests should be centralised and coordinated via the home supervisor. ACA appreciates this requirement arises out of situations where there are deteriorating financial conditions and severe non-cooperation by the home supervisor. We therefore believe that the legal text should better reflect those concerns and perhaps put in place a framework or process around such requests. If companies start to receive direct and possibly conflicting requests from different authorities, this could severely distract from the supervisory review process. Additionally, ACA believes that these provisions should not apply to cases where a supervisory college exists as it could undermine supervisory convergence by allowing for different supervisory approaches for different business structures. Furthermore, we find that the inclusion of reinsurance undertakings within the scope of these new requirements is incompatible with the nature of the reinsurance business. The Solvency II Directive defines reinsurance as the activity of accepting risks ceded by another (re)insurer. By nature, reinsurance is a business-to-business activity that is intrinsically cross-border, we find that the current proposals fail to recognise the specificity of reinsurers' business models.
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