CNP Assurances Holding
CNP Assurances group is a European and global Insurance player headquartered in France.
ID: 019519094351-45
Lobbying Activity
5 Sept 2025
We express strong support for the objectives of the Solvency II review, emphasising the need for a risk-sensitive prudential framework that enhances the competitiveness of the European insurance market. We highlight the importance of maintaining a level playing field, reducing operational burdens, and promoting long-term investment to enable insurers to fully contribute to economic financing. While welcoming some positive proposed changes, we also raise concerns about certain provisions that may undermine these goals and add complexity without clear prudential benefits. In particular: Proposals on LTEI are insufficient to ensure the success of the measure: While the Commission supplemented LTEI no forced selling test approach with the coexistence of EIOPAs methodology, they remain excessively restrictive. The exclusion of financial bonds, limitations on funds and the severity of the stresses contribute to making the test disproportionately stringent. The approaches based on duration and liquidity buffer are based on overly restrictive criteria, notably with a duration threshold set at ten years for the life approach and the exclusion of assets held through liquid investment vehicles in the non-life approach. Finally, the scope of funds eligible for simplified look through approach needs to be significantly widened. An appropriate definition of the VA is crucial to encourage long-term investments. The proposed definition of the CSSR should be improved as it does not correctly reflect the impact of spread widening on own funds. Risk margin: The reduction of the lambda factor to 96% is a positive step forward but still falls short of the industrys expectations. The 50% floor should be dropped, as it unduly restricts the effectiveness of the lambda in supporting long-term guarantees. A lambda of 92.5% with no floor would allow the industry to remain competitive both in countries without a risk margin or with a lower calibration. The changes in the Interest Rate Risk SCR remains significantly overstated and might even become unbearable under certain market circumstances. It will substantially weight on the benefits of the review, while creating a risk of unlevel playing field with other jurisdictions where such changes have not been foreseen or adopted. Beyond LTG elements, many proposals are seen as restrictive and operationally complex, particularly regarding reporting, the recognition of reinsurance in the standard formula or best estimates. In many cases, the proposed changes are neither necessary nor justified and would only increase operational and reporting burdens, disrupt the EU insurance market, impair its competitiveness and the SIU goals. It is regrettable that these points were not subject to more in-depth discussions. In particular, the ability for supervisors to challenge availability of group EPIFP is not appropriate and could only lead to an unjustified deletion of own funds. Changing the treatment of EPIFP would undermine the consistency of the prudential framework, eliminate a key incentive to provide long-term guarantees by locking up capital in legal entities, preventing its use for economic growth or closing protection gaps. It will lead to additional burden for the industry, divergent supervisory practices, gold-plating or even inefficient group restructure. Internal models: Introducing artificial bias into internal models through the review such as the derecognition of capital contingent instruments, standard formula reporting or the application of the enhanced prudency principle when overshooting is already avoided would undermine one of the most significant risk management achievements of Solvency II. Minimum group SCR: The Commission is bound by the Level 1 text to specify the application of the group minimum SCR. It should clarify the elimination of the non-economic double counting of risks, which has no equivalent globally and would unfairly disadvantage European groups.
Read full responseResponse to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector
21 Jul 2025
We welcome the European Commissions initiative to strengthen the supplementary pensions sector as part of the Savings and Investments Union. CNP Assurances is a leader in the insurance sector in Europe, particularly in life and supplementary pensions products. The Savings and Investment Union aims to accelerate financial integration in the UE. Given the key role of institutional investors in this dynamic, CNP Assurances is fully committed to this ambition, mobilizing 298 billion to serve the real and sustainable economy in Europe. European life insurance products offer guarantees and options tailored to all savers profiles, with a very protective legal framework and duty of advice at both European and national levels. These products are very popular with savers. They enable us to invest in a wide range of asset classes (corporate and sovereign bonds, equities, real estate and infrastructure, as well as unlisted assets and private equity) not only to support the ecological and digital transition but to support all industries sectors. To strengthen long-term investment in Europe, we support the proposal put forward in the Draghi and Noyer reports to promote a new class of European savings product in the form of a label, given the disparities between member states in terms of taxation, risk appetite and purchasing power of European citizens, and pension systems. We strongly support the labelling of the Plan dEpargne Retraite (PER) under the Finance Europe label. It allows investors to invest in riskier asset classes, while remaining competitive in terms of cost and performance. The PER makes a significant contribution to corporate financing, with over 80% of assets invested in the EU. This supplementary pension product covers 11 million French holders. In 2024, France had more than 15.4 million retirees, according to the national pension system. The aging population is a major challenge. At CNP Assurances, we are aware of the implications this demographic shift has on pension systems. We promote the PER as a long-term savings solution to accompany retirement and ageing well. The consumers could be sensitive to a European label like Finance Europe. In France, a company is under no obligation to set up a retirement savings plan for its employees. If it does, the PER can be either mandatory or optional. Since January 1, 2025, certain companies (with conditions on headcount, legal form and financial results) have been obliged to set up a value-sharing scheme. The PER is not compulsory in this context but can be used as a complement if the company so wishes. For those who are not covered (self-employed workers, or companies below the thresholds), it might be appropriate to guarantee equivalent tax incentives, in order to make membership of a retirement savings plan attractive and accessible. The French Info-Retraite portal allows to track pension systems and to provide clear dashboards. It will be gradually extended to cover supplementary pension products. Promoting interoperability between member states' systems is understandable, particularly to support international careers. But we would underline the need for a flexible technical solution that can adapt to existing national systems and avoid too high implementation costs. Finally, we recommend avoiding regulatory overburden, in line with the EUs simplification goals. The IORP II framework provides a robust and prudential framework for managing long-term liabilities. We caution against introducing an explicit duty of vigilance requirement, which could lead to excessive obligations. However, easing constraints on long-term investment appears to us as essential under the Solvency 2 Regulation.
Read full responseResponse to Savings and Investments Union
7 Mar 2025
CNP Assurances is a leader in the insurance sector in Europe. The Savings and Investment Union aims to accelerate financial integration in the UE. Given the key role of institutional investors in this dynamic, CNP Assurances is fully committed to this ambition, mobilizing 298 billion to serve the real and sustainable economy in Europe. European life insurance products offer guarantees and options tailored to all savers profiles, with a very protective legal framework and duty of advice at both European and national levels. These products are very popular with savers. They enable us to invest in a wide range of asset classes (corporate and sovereign bonds, equities, real estate and infrastructure, as well as unlisted assets and private equity) not only to support the ecological and digital transition but to support all industries sectors. To strengthen long-term investment in Europe, we support the proposal put forward in the Draghi and Noyer reports to promote a new class of European savings product in the form of a label, given the disparities between member states in terms of taxation, risk appetite and purchasing power of European citizens, and pension systems. In France, the Plan d'Epargne Retraite (PER) could be labeled. It allows investors to invest in riskier asset classes, while remaining competitive in terms of cost and performance. The PER makes a significant contribution to corporate financing, with over 80% of assets invested in the EU. For deploying long-term savings, and strengthening the EU's economic sovereignty and competitiveness, the Commission could propose ambitious measures on existing regulations considering the challenges of regulatory simplification, security and sovereignty: - Developing and relaunching the European securitization market. Indeed, the current legal framework and the absence of a market are holding back investor involvement in the securitization market. For insurers, a revision of the prudential framework for securitized assets, and of the regulation on STS Securitization concerning due diligence, are essential. - Easing constraints on long-term investment. In the context of European discussions on level 2 of the modified Solvency 2 framework, it is essential to improve and simplify the liquidity test and more generally, the criteria for making equities eligible for the LTEI scheme. Furthermore, the calculation of the SCR of a securitized asset must be consistent with the calculation of the SCR of a bond with an equivalent rating. - We stress the need to maintain national supervision, given the specific nature of the products, taxation, pension and healthcare systems in the various Member states. What's more, the current supervisory system for the insurance sector has never demonstrated any shortcomings or flaws in terms of solvency and financial equilibrium. - RIS. As part of the trialogue discussions, we would ask you to simplify the text about the point of sales, to achieve the objective of facilitating access to capital markets for retail customers. In addition, the existing Product Oversight Governance processes should be kept simple (removal overarching principles, inducement tests and peer groups, only national benchmarks), while ensuring Value for Money and customer protection. -The financial education of European citizens needs to be reinforced. Our industry's contribution is essential, but it is not enough on its own, and must be carried out in cooperation with national public authorities. - It would be illusory to think that the lack of financial education can be compensated for by prolix pre-contractual and contractual documentation, in which even a well-informed customer gets lost. Let's simplify this documentation by offering all the transparency necessary for a good understanding and knowledge of the products. - Harmonization and simplification of the various texts is fundamental, particularly in terms of sustainability (without weakening the Green Deal).
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