Assuralia, beroepsvereniging van verzekeringsondernemingen
Assuralia
Assuralia, the Belgian insurance association, was established in 1920.
ID: 0026376672-48
Lobbying Activity
Meeting with Tilman Lueder (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
7 Nov 2025 · Solvency, health insurance, natural catastrophe insurance and pensions
Response to Digital package – digital omnibus
10 Oct 2025
The Belgian insurance industry fully supports DORA's goal of digital operational resilience. The sector has already made significant investments in digital operational resilience and stands ready to meet these challenges. However, the current incident reporting requirements introduce unnecessary costs and administrative burdens, particularly for insurers and smaller firms. Targeted simplifications are therefore essential to maintain high standards of digital operational resilience while ensuring efficiency and proportionality, so that compliance efforts remain commensurate with the risk, activities, operations and size of the insurer. Therefore, the following simplifications are to be taken on board in the future Digital Omnibus: 1. Guarantee stability in reporting templates: frequent changes to reporting templates create additional adaptation costs and any modifications should therefore avoid unnecessary template changes. All insurers already developed internal processes and designed software to collect, consolidate and report ICT-incident data efficiently. More broadly, while the intention to uphold high standards is appreciated, introducing complex or disproportionate legal requirements that later require simplification can result in significant and avoidable costs for companies. To ensure that regulatory objectives are achieved efficiently and sustainably, legislation should be accompanied by robust impact assessments and should consider cost-effectiveness and proportionality from the outset. 2. Ensure coherence and prevent reporting duplication: reporting obligations should be coherent across legal frameworks and duplicated reporting (e.g. under DORA, GDPR, CRA) should be eliminated. Currently, the same data has to be reported to several authorities. Streamlining these requirements will reduce inefficiency and allow firms to focus on incident resolution rather than redundant paperwork. 3. Streamline the current templates in a single European template for incident reporting: reporting ICT-incidents currently requires manual input into multiple templates, increasing the administrative burden at the very moment resources are needed to resolve incidents. A unified European template, aligning and streamlining all reporting regimes (DORA, GDPR, CRA, etc.), would significantly improve efficiency. The insurance sector urges the European Commission to adopt these targeted simplifications. By prioritizing stability for insurers, coherence, and proportionality, the DORA simplification can achieve its objectives without imposing unnecessary burdens, enabling insurers to focus on resilience, innovation, and competition (e.g. enhancing their ability to serve policyholders and remain competitive globally). Next to ICT-incident reporting, there is huge potential for burden and cost reduction in the reporting exercise connected to third party risk (i.e. the register of information) and other areas, without affecting the high standards of digital operational resilience that DORA currently sets. For more information, see the document attached. These proposals directly contribute to the European Commissions Strategic Foresight report entitled Resilience 2.0, which calls for adaptability in crisis, digitalisation and a coherent approach to help the EU thrive (i.e. becoming more competitive and innovative) amid turbulence and uncertainty. The Belgian insurance sector already demonstrates a high level of digital operational resilience, but there still is ample room for simplification in DORA, which would allow resources to be redirected to other matters like competitivity and innovation.
Read full response5 Sept 2025
The Belgian insurance association Assuralia supports the response from Insurance Europe, to which Belgian insurance companies have collaborated and contributed.
Read full responseMeeting with Lauro Panella (Cabinet of Commissioner Maria Luís Albuquerque), Nuno Vaz (Cabinet of Commissioner Maria Luís Albuquerque), Philippe Thill (Cabinet of Commissioner Maria Luís Albuquerque) and Febelfin
15 May 2025 · Thematic roundtable with Febelfin and Assuralia on the Savings and Investment Union
Response to Technical description of important and critical products with digital elements
15 Apr 2025
Assuralia considers that the applications (web and mobile) and client portals that are currently used by insurance companies to support the provision of insurance services do not fall within the scope of the CRA regulation. Consequently, they also do not fall into the categories of important products and critical products with digital elements, as referred to in Articles 7 and 8 of the regulation, which are the subject of the Commission's current consultation. Furthermore, the CRA requires that products with digital elements be made available on the market, which implies "the provision of a product with digital elements intended to be distributed or used in the Union market as part of a commercial activity" (see the definition in Article 3(22) of the CRA). Recital No. 15 provides certain indicators to determine whether a service is provided in the course of a commercial activity. However, insurers do not charge a price for the applications and web services that support their insurance services, neither for technical support services. Finally, even if insurers applications were nonetheless considered products with digital elements made available on the market within the meaning of the CRA, it should be considered that the application of the CRA may be limited or excluded in their case, according to Article 2(5) of the CRA, due to their submission to and compliance with specific sectoral rules (namely, those imposed by the DORA Regulation), which ensure a level of protection equivalent to that of the CRA.
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
26 Mar 2025
Dear Members of the European Commission, We are writing on behalf of the Belgian insurance sector to express our strong support for the proposed omnibus simplification package. We strongly support the European Commissions efforts to reduce the regulatory burden that the omnibus simplification package aims for. We believe that this initiative is a significant step towards enhancing regulatory efficiency and reducing administrative burdens across the industry. We particularly appreciate the Commission's efforts to engage with stakeholders throughout the development of this package. This collaborative approach ensures that the proposed measures are both practical and beneficial for all parties involved. We have discussed this simplification proposal with our Members, Belgian insurance and reinsurance companies, and would like to highlight the following concerns related to: Scope, Substantially reduce number of data points, EU Taxonomy reporting templates, Materiality filter, Phased-in approach CSRD, CSDDD, Sustainability Risk Plans. Please refer to our detailed comment letter in attachment. Furthermore, we refer to the comments of Insurance Europe on this consultation. In conclusion and in general, we strongly support the proposed omnibus simplification package and look forward to its positive impact on the insurance sector and the broader financial industry. We remain committed to working with the European Commission to ensure the successful implementation of these important reforms and are, at the same time, hoping that you will take our feedback into account in your further assessment. Thank you for your attention to this matter.
Read full responseResponse to Claims history statement template for motor insurance
22 Feb 2024
Please find attached Assuralia's response. Best regards.
Read full responseResponse to Reporting reduction package - amendments to the ESA, ESRB and InvestEU Regulations
28 Dec 2023
The changes to Regulation 1094/2010 establishing EIOPA are important for the Belgian insurance sector. The initiative to reduce the reporting burden is very much welcome, and additional observations are made below. Art. 29 and 30: The proposed amendments will not provide relief in the short term because they contain a mandate to identify and propose the elimination of redundant and obsolete reporting requirements in the application of regulatory and implementing technical standards, guidelines, recommendations, etc. Furthermore, the amendments include an assessment of the effectiveness and convergence of national reporting requirements through peer reviews. Yet, there is no specified timeframe and it is recommended to initiate the process rapidly. This process should be linked to a specific reporting obligation to the European Commission (EC), Council, and European Parliament (EP), within, for example, one year. Art 35a: This provision could have an immediate effect because it directly obliges EIOPA and the NSAs concerned to exchange information if there is a legal basis for the request for information from the requesting authority. The industry has concerns related to the extent of the data sharing obligations referred to in paragraphs 1 and 6, because the sharing is not limited to an objective/purpose. Therefore, the industry highlights that the focus of convergence should be on reducing the reporting burden for companies. It should not result in additional reporting requirements or a tendency towards increased conservatism. The primary and only goal of data sharing should be the reduction of the reporting burden for companies. Besides, it is stressed that insurance companies must stay in control of their data. Therefore, it is suggested to integrate data lineage processes in the proposal. Besides, there should be greater transparency towards insurance companies with regards to the transfer of their data (to which authorities and what for). Moreover, insurance companies should be able to correct erroneous data and oppose to data sharing practices. Concerning paragraph 7 the Belgian insurance sector does not support granting data access to competitors, researchers etc... The content of the paragraph goes beyond the purpose of this proposal. The sector is concerned that access to data in real time increases the risk of insider information. There are also competition concerns. Information connected to pricing or risk management were obtained after years of work and the incentive to develop this information should be maintained. Moreover, when there are competition related complaints, insurance companies must prove that the information was not communicated by them. This is impossible if data of companies is shared without them maintaining control over the data and having knowledge thereof. In addition, the sector is concerned about the transfer of data outside of the European Union within the context of the existing safeguards in the Data Governance Act. Furthermore, the drafting of this paragraph is too vague from a legal perspective, particularly regarding the meaning of entities with a legitimate interest in such information. Additionally, anonymisation of data is not sufficient as a safeguard particularly in the case of privacy and competition. A high level of cybersecurity amidst the data sharing provisions is crucial. Increased digitalisation amplify cyber risks. Therefore, Arts. 5(3)(b) and 5(3)(c) of the Data Governance Act should be integrated in the proposal, at the very least and higher cybersecurity standards would be welcome.
Read full responseResponse to Open finance framework
31 Oct 2023
FIDA should exclude pension data when already shared under an existing national pension tracking service (NPTS). In several MSs, data related to occupational pensions are already made accessible to customers and third parties through a NPTS. In Belgium, a well-functioning and well-established NPTS covers the first pension pillar (statutory pensions) and the second pension pillar (occupational pensions). FIDA will oblige data holders to develop a totally new data sharing framework for pension data, hereby ignoring the already existing NPTS framework at national level. There is no need to introduce a new data sharing framework where such a framework already exists. This would be disproportionately burdensome and costly for pension data holders such as insurers and would not provide added value. Rather than putting in place such a parallel circuit to share pension data, FIDA should acknowledge the merits of those existing NPTS and should further build on them. It should therefore exclude pension data that data holders already share under an existing NPTS. The obligation to share data in real-time should not apply to data that is not generated in real time. Any real time data sharing obligation should only be introduced when data is also generated in real time. E.g., unlike payment account data, pension rights data cannot be provided in real time to customers, nor does it need to be. Most customers only need to have a general idea of the expected pension rights at retirement date. This prognosis changes slowly over time. The level of the accrued pension rights also changes little over time and is less relevant due to the long-term nature of an occupational pension scheme. So, an insurer mostly only provides an update once a year. FIDA applied to the insurance distribution channel leads to significant data gaps, jeopardising datasets accuracy. The insurance distribution channel will not always enable linking data to a customer, jeopardising dataset's accuracy. Insurers do not always have personal data or contracts concluded by insurance intermediaries. Insurance intermediaries store personal data without insurers having access to it. Insurers store data on products and risks underwritten and not all related personal data. Many intermediaries will not be obliged to share data because they qualify as microenterprises or small or medium-sized enterprises, leading to significant data gaps and preventing linking data to a customer Art. 2(3). Datasets often contain gaps and sometimes mistakes. A "unique identification number" (e.g., the Belgian "national registration number") would increase data accessibility and guarantee accuracy. Yet, the Belgian authorities are not obliged to share these data with insurers. Except for few legally defined purposes and despite many requests, Belgian insurers are not allowed to gather, store and use national registration numbers to identify their customers. This is a major obstacle to effective data sharing. Clarifications are needed to make sure the objectives of FIDA are met and to prevent legal uncertainty. The understanding of the concept of "data quality" (Art. 5(3)(a)) differs within the sector (Belgian National Bank vs. the Basel Committee on Banking Supervision 239 standard). Compensation is defined in FIDA, but it is unclear if it covers the one-off implementation costs. Costs could be passed-on to the customer which is contradictory to FIDAs objectives. Financial Data Sharing Schemes (FDSS) cause high costs and burdens for data holders. Data holders will have to be members of multiple FDSS and comply to all obligations/rules (e.g., ensure interoperability with several systems). This will cause high costs and burdens for data holders, jeopardise interoperability and legal certainty. The value for money principle will be difficult to implement in a digital environment for services linked to FIDA, e.g., the exchange of data or comparison of offers in return of high costs.
Read full responseResponse to Retail Investment Package
22 Aug 2023
Many provisions included in the proposals will make consumers investment journey longer, more complicated, and intimidating than before. Steps were added to the very long purchase process under both the suitability and appropriateness tests, the reporting and record keeping requirements are increased. This additional bureaucracy will discourage consumers from investing and insurance distributors from giving advice (even from distributing IBIPs), and will make financial services less cost-efficient, as compliance costs will increment, and services will become more expensive for retail investors. New processes are also introduced for the manufacturer of products, like the assessment of the risk of misunderstanding of the main features by the customers. The lack of clear definition of some key elements such as retail customers leave the door open to interpretations and legal uncertainties. The proposals lead, in practice, to a very broad ban on inducement. We fear that the proposed requirements for the payment of inducements under the new best interest test for advised sales will lead to a non-inclusive investment world, as it will be impossible for consumers to consider shopping around and taking investment decisions without having to pay an upfront fee, leaving fee-based advice to the most fortunate consumers. We support the promotion of value for money principles under certain conditions: the development of benchmarks must remain at a national and product level only, knowing the diversity of products between FMPs and markets across Europe and the fact that NCAs already have the necessary tools and powers to identify outliers in their own market. There is no need for additional burden on market participants. We also fear that the use of benchmarks will lead to a restriction of consumer choices by destroying competition and innovation between FMPs. Sometimes value encompasses more than just costs and returns. The substantial changes made by the RIS will weigh more heavily on small structures (at the level of insurance companies and intermediaries) and it is necessary to envisage that these structures may come to cease their activities. This will decrease competition in the market, to the disadvantage of the customer. The distinctive benefits of IBIPs need to be recognised, while the current proposals often do not fit for insurance, use a very fund-oriented language (e.g., portfolio diversification) and do not consider the diversity of insurance distribution systems. Assuralia also wishes to emphasize that information obligations concerning (occupational) pension products should remain at a national level only, knowing that they can be offered by insurance companies and occupational pension funds and the fact that they are already strictly regulated at member state level and are strongly interlinked with the national social and fiscal framework, which is a member state competence. More can be done to make disclosures more user-friendly and address the issue of information overload. Assuralia would like to highlight that under the KID, the pages are limited to 3 and are already used. If more information is needed, it wont be possible to integrate new sections such as one on sustainability without deleting other information to be provided in the KID. The information to be provided for a Multi option product is not always clear. Information must remain readable and consumer friendly. We strongly support the use of what already exists both at European (SFDR RTS templates) and at national level. At this end, Assuralia would like to share with the EC what exist in Belgium concerning non-IBIPs products, as it could help developing this kind of document at EU level. The transposition dates are tight and would make impossible for the industry to comply properly in due time. Too many details are left under level 2 and 3 and this will increase the legal uncertainties and could be detrimental for consumers and insurers.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
28 Apr 2023
Assuralia welcomes the Commission draft delegated regulation, please find attached the feedback from Assuralia.
Read full responseMeeting with Isabelle Perignon (Cabinet of Commissioner Didier Reynders)
19 Apr 2023 · consumer protection and the retail investment strategy
Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)
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 law and are generally supported.
However, the proposal to require the development and maintenance of recovery plans in a pre-emptive manner is excessive. Insurance companies should not be required to draft pre-emptive recovery plans during normal course of business. A permanent requirement of pre-emptive recovery planning risks to be very burdensome and inefficient. The development of a recovery plan should be triggered by the NSA where there are clear indications that the financial condition of the insurance company is deteriorating. As is currently the case in Belgium, the requirement to draft a recovery plan should be part of the early intervention measures supervisors can dispose of.
In Belgium, the NSA can currently ask for a recovery plan when the financial position of a company deteriorates. The NBB can demand to execute this plan if there is the risk that a company will no longer comply with Solvency II in the next 12 months, e.g., a likely breach of the SCR.
For detailed feedback, Assuralia refers to the Insurance Europe submission, to which Belgian insurance companies contributed.
Read full responseResponse to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)
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 specifications still need to be further developed in the Delegated Regulation of Solvency II.
The Belgian insurance sector appreciates the effort of the European Commission to improve the long-term investment capacity of insurance companies by:
Considering improvements to the SCR long-term equity submodule;
Lowering the risk margin;
Proposing an appropriate shock for the SCR interest rate risk; and
Ensuring the capital requirements remain risk based.
However, also improvements to the European Commission's proposals have been identified, in relation to the:
Volatility adjustment (e.g., the risk correction method);
Risk free rate (e.g., the convergence factor for extrapolation);
SCFR & reporting requirements; and
Internal model requirements.
For detailed feedback, Assuralia refers to the Insurance Europe submission, to which Belgian insurance companies contributed.
Read full responseResponse to Requirements for Artificial Intelligence
5 Aug 2021
Please find enclosed Assuralia's contribution.
Read full responseMeeting with Tom Vandenkendelaere (Member of the European Parliament)
6 May 2021 · insurance & sustainability in digitalisation
Response to Digital Operational Resilience of Financial Services (DORFS) Act
16 Feb 2021
Please find enclosed the Assuralia's position (Belgian Insurance sector) on the DORA proposal.
Read full response