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Insurance Ireland

Insurance Ireland represents the insurance sector in Ireland, advocating for 131 member firms serving 25 million customers across 110 countries.

Lobbying Activity

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque), Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

14 Jan 2026 · Exchange on regulatory developments relevant for insurers

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

14 Jan 2026 · Savings and Investment Union (SIU) Strategy

Meeting with Helene Bussieres (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

20 Nov 2025 · SFDR

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

22 Oct 2025 · Savings and Investment Account

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

23 Sept 2025 · SIU

Insurance Ireland Urges Inclusive European Savings Account Framework

8 Jul 2025
Topic — The EU is developing a standard blueprint for retail savings and investment accounts.
Message — Insurance Ireland wants insurance products included in the new EU framework. They advocate for tax reforms to ensure fair competition with bank deposits. The group suggests using successful models like the UK's Individual Savings Accounts.12
Why — This would allow insurers to compete more effectively for retail savings.3
Impact — Banks would lose the tax advantage their deposit accounts currently enjoy.4
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Meeting with Ciaran Mullooly (Member of the European Parliament)

1 Jul 2025 · Multiple issues

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

30 Jun 2025 · Exchanges on regulatory topics on insurance

Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Rapporteur)

4 Jun 2025 · Retail Investment Strategy

Meeting with Regina Doherty (Member of the European Parliament)

20 May 2025 · Securitisation

Meeting with Billy Kelleher (Member of the European Parliament)

28 Apr 2025 · Securitisation

Response to Savings and Investments Union

7 Mar 2025

Insurance Ireland is the representative organisation for insurance undertakings operating in Ireland. As well as serving Irish businesses and consumers, Ireland is also a thriving global hub for insurance, reinsurance and InsurTech. Irish insurers are some of the leading providers of cross-border services in the European Union. Ireland is the fourth-largest insurance market and one of the largest reinsurance markets in the European Union. Insurance Ireland is supportive of recent initiatives published by the European Commission, including the plan to create a Savings and Investments Union (SIU), which aims to stimulate retail investors engagement and participation in the capital markets. As evidenced in the reports prepared by Enrico Letta and Mario Draghi, the level of retail investor participation in EU capital markets remains very low compared to other developed countries economies, despite high individual savings rates in Europe. Accordingly, consumers may currently not fully benefit from the investment opportunities offered by capital markets, thus missing potential wealth creation opportunities. The insurance industry is a key enabler for economic activity and social wellbeing and can offer and provide cover for many and different types of risks. At the same time, insurers, together with pension funds, are among the top institutional investors in the world. Insurers are particularly important for small and medium enterprises (SMEs) who do not have the means and structures to manage and mitigate risks on their own or the financial strength to compensate for potential losses. Insurance also entails significant amounts of financial flows from the insured to the insurer, in terms of premia, and from the insurer to the insured, in terms of benefits. Until the benefits are paid, the insurance premia are directed to the real economy, as well as to the financial markets. Taking into consideration the above, the insurance industry could be a key contributor and enabler to achieving the SIU objectives. Insurance Irelands detailed submission is attached.
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

6 Mar 2025 · Exchange with Insurance Ireland on regulatory developments

Meeting with Martine Kemp (Member of the European Parliament)

5 Mar 2025 · General Meeting

Meeting with Regina Doherty (Member of the European Parliament, Shadow rapporteur)

5 Mar 2025 · FIDA

Meeting with Billy Kelleher (Member of the European Parliament) and Banking Payments Federation Ireland and Irish Funds Industry Association CLG

5 Mar 2025 · Savings and Investment UNion

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)

5 Mar 2025 · Insurance

Meeting with Dirk Gotink (Member of the European Parliament)

20 Feb 2025 · Solvency 2, IRRD, Savings and Investment Union

Meeting with Thomas Bajada (Member of the European Parliament)

20 Feb 2025 · Work in the ECON Committee

Meeting with Nina Carberry (Member of the European Parliament) and Banking Payments Federation Ireland

2 Oct 2024 · Irish Financial Services

Meeting with Aodhán Ó Ríordáin (Member of the European Parliament)

2 Oct 2024 · Insurance and pension policy

Meeting with Michael Mcnamara (Member of the European Parliament)

2 Oct 2024 · Irish Financial Services Breakfast Roundtable

Meeting with Barry Andrews (Member of the European Parliament) and Banking Payments Federation Ireland and Irish Funds Industry Association CLG

2 Oct 2024 · Financial Services

Meeting with Jonás Fernández (Member of the European Parliament)

2 Oct 2024 · Capital Markets Union

Meeting with Billy Kelleher (Member of the European Parliament)

25 Sept 2024 · Insurance policy / CMU

Meeting with Regina Doherty (Member of the European Parliament)

26 Jun 2024 · Innovation and competitiveness

Meeting with Maria Walsh (Member of the European Parliament)

26 Jun 2024 · Insurance Policy

Meeting with Barry Andrews (Member of the European Parliament)

19 Apr 2024 · Insurance Ireland President's Lunch

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

6 Mar 2024 · Solvency II, AML Regulation, Exchange on the right to be forgotten

Meeting with Laura Ballarín Cereza (Member of the European Parliament)

5 Mar 2024 · Consumer protection financial services

Meeting with Alfred Sant (Member of the European Parliament)

5 Mar 2024 · Retail Investment Strategy

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Patricia Reilly (Cabinet of Commissioner Mairead Mcguinness)

5 Mar 2024 · Exchange views on the future steps of building the Capital Markets Union

Response to Claims history statement template for motor insurance

22 Feb 2024

Insurance Ireland is the representative association for insurance companies in Ireland. We welcome the opportunity to provide feedback and our main concerns are as follows: 1) The claims history statement should be on request only, as Article 16 of Directive (EU) 2021/2118 states. 2) The claims history statement should be in relation to cross-border scenarios only and should not be applicable in the domestic Irish market where there are already extensive regulatory requirements around communication of claims history to policyholders. The provision by insurers of two claims history statements in different formats would serve to confuse rather than inform policyholders. 3) The claims history statement should apply to car insurance policies for private individuals only and not to fleets or commercial vehicles where the amount of data required is not generally available to insurers, e.g. insurers do not have extensive information on every driver or vehicle under a fleet policy. 4) The claims history statement should relate to drivers who hold their own policies only. We have concerns about the designated driver field in particular. Insurers do not generally have as much information on named drivers as they have on policyholders and, in any case, there are GDPR concerns involved in sharing named driver information in this context. Named drivers also typically have breaks in cover, which is an added complication. 5) As a general comment, the document is more detailed than necessary. There are 27 fields of information, only 6 of which do not need to be completed where the information is not available to the insurer. Section 7 - identification number - should be added to this list of 6 fields as people in Ireland do not have identification numbers and private sector organizations in Ireland are not permitted to collect the Personal Public Service number, which people have to access public services. We would suggest that Section C - Designated Driver(s) - should be deleted in the interests of conciseness and to avoid the complications outlined in point 4 above. ENDS
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Meeting with Deirdre Clune (Member of the European Parliament)

13 Feb 2024 · Right to be Forgotten for Cancer Survivors

Insurance Ireland urges sector-specific GDPR guidance and transfer certainty

29 Jan 2024
Topic — The European Commission is evaluating the GDPR's application six years after its implementation.
Message — The organization seeks sector-specific guidelines for insurers and a stable framework for international data transfers. They also recommend tailoring data access responses to what the individual specifically requests.123
Why — Clearer guidelines and streamlined requests would provide greater legal certainty and lower administrative costs.45
Impact — Individuals might receive less comprehensive information if access requests are limited to specific items.6
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Meeting with Alfred Sant (Member of the European Parliament, Shadow rapporteur)

6 Dec 2023 · Reporting Requirements in the fields of financial services and investment support

Meeting with Erik Poulsen (Member of the European Parliament, Shadow rapporteur)

29 Nov 2023 · Reporting requirements in the insurance sector

Insurance Ireland urges phased approach and clarity on EU financial data access rules

31 Oct 2023
Topic — EU regulation extending customer financial data sharing to insurance and other sectors.
Message — Insurance Ireland requests a phased implementation starting with motor and home insurance, at least 3.5 years total timeline, and EU-wide interoperable standards with local flexibility. They seek clarity on data protection requirements, scheme operations, and whether customers can control what data is shared.1234
Why — This would give insurers more time to develop systems and avoid large complexities and costs.56
Impact — New third-party data providers gain access without comprehensive regulation, potentially harming consumer protection.78
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Meeting with Frances Fitzgerald (Member of the European Parliament, Shadow rapporteur)

5 Oct 2023 · FIDA

Insurance Ireland warns EU against full ban on commissions

28 Aug 2023
Topic — The European Commission is proposing new rules to boost retail investor participation.
Message — The organization opposes a total ban on sales commissions to ensure professional advice remains accessible. They also request that consumer disclosure rules be simplified to prevent an overwhelming volume of information.12
Why — Maintaining commissions allows insurers to avoid restructuring their distribution networks and reduces administrative expenses.34
Impact — Consumers may receive biased advice from sellers who are incentivized by third-party commissions.5
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Meeting with Billy Kelleher (Member of the European Parliament)

4 Jul 2023 · Retail Investment Strategy

Meeting with Frances Fitzgerald (Member of the European Parliament)

30 Jun 2023 · Retail Investment Strategy

Meeting with Frances Fitzgerald (Member of the European Parliament)

1 Jun 2023 · Retail Investment Strategy

Meeting with Chris Macmanus (Member of the European Parliament, Shadow rapporteur)

1 Mar 2023 · Solvency II

Meeting with Jonás Fernández (Member of the European Parliament, Shadow rapporteur)

1 Mar 2023 · EU Banking Package 2021

Meeting with Deirdre Clune (Member of the European Parliament)

28 Feb 2023 · Right to be Forgotten

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

28 Feb 2023 · Solvency II Review

Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

28 Feb 2023 · Insurance Regulation: Solvency II

Meeting with Mairead McGuinness (Commissioner) and

2 Dec 2022 · Introductory meeting

Meeting with Ciarán Cuffe (Member of the European Parliament)

14 Oct 2022 · European Green Deal (Staff level)

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

29 Sept 2022 · Solvency II

Meeting with Nicolás González Casares (Member of the European Parliament, Shadow rapporteur) and RPP Group

28 Sept 2022 · cancer

Meeting with Chris Macmanus (Member of the European Parliament, Shadow rapporteur)

27 Sept 2022 · Solvency II

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion) and Banco Santander, S.A. and

28 Jun 2022 · Joint exchange of views on the Data Act

Meeting with Chris Macmanus (Member of the European Parliament, Shadow rapporteur)

28 Apr 2022 · Solvency II

Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

27 Apr 2022 · Insurance Regulation: Solvency II

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

20 Jan 2022 · Solvency II

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

13 Jan 2022

Insurance Ireland (II) appreciates the opportunity to provide its feedback on the European Commission’s (EC) proposal establishing a framework for the recovery and resolution of (re)insurance undertakings (hereafter: IRRD). II notes that the EC presented IRRD, but did not present a proposal for the harmonisation of Insurance Guarantee Schemes (IGS). II regrets this decision of the EC as it believes that a comprehensive EU-wide regulatory framework should also include IGS. Solvency II (SII), already, provides for safeguards and measures for the recovery and resolution of insurance undertakings. Nonetheless, a harmonised IRRD can be a valuable edition. However, certain principles need to be ensured: • The provisions focus on insurance groups where a failure might have an impact on the functioning of the market or present substantial risk to public interest; • The degree of harmonisation prevents double-standards, regulatory arbitrage and substantial gold-plating; • The integrity of SII is maintained. The IRRD proposal includes all (re)insurance groups in its scope. II is of the strong opinion that reinsurance and captive (re)insurance undertakings should be exempted. Due to the nature of the business, II does not believe that requirements in addition to those, which already exist under SII, should apply. Despite this limitation, II strongly supports the group approach which the EC takes. The IRRD further foresees minimum market coverages applicable at national level (70% for resolution and 80% for recovery measures). II is not convinced that a pre-defined national market share is fit-for-purpose for the risk-based nature of the supervisory regime. Nonetheless, it is absolutely indispensable that group recovery and resolution measures prevail at subsidiary level. National supervisory authorities (NSAs) which are supervising subsidiaries of groups where the subsidiary is subject to a group recovery or resolution plan must not face additional requirements at national level. Any concerns from NSAs should be addressed in the college of supervisors or the equivalent structure for resolution authorities. Maintaining this principle will ensure consistency in the treatment of policyholders across jurisdictions and fair competition.. Finally, II would like to emphasise the importance of maintaining the integrity and credibility of SII. At no stage should the IRRD undermine the functionality of the SII supervisory ladder. The IRRD suggested early intervention tools for the recovery planning of insurance undertakings. These measures will create a significant additional burden without an appropriate added value for the vast majority of insurers and policyholders and, implicitly increase the SCR above the fundamental eligibility standard of SII, the 99.5% Value-at-Risk. Furthermore, the EC proposes powers for resolution authorities to address or remove impediments to the resolvability of insurance undertakings and to put an undertaking into resolution before a breach of the Minimum Capital Requirement (MCR). This provision contradicts the supervisory intervention ladder under SII and undermines the integrity of the NSA and potential recovery strategies. The resolution authority should only be able to intervene where the MCR is breached and the NSA starts procedures to withdraw authorisation of an insurer. The “early-resolution” might also undermine recovery strategies and improvements to the benefit of policyholders and thereby conflict with the efforts of the undertaking which have been approved by the NSA. II calls on Co-Legislators, including the EC, to amend the EC proposal to ensure that the IRRD can fulfil its purpose in a targeted and efficient manner. II stands ready to support this process. Insurance Ireland is the representative body of the Irish insurance industry. Irish insurers are serving more than 25 million customers in Ireland and globally across 110 plus countries.
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Insurance Ireland urges Solvency II reforms to boost competitiveness

11 Jan 2022
Topic — Review of EU Solvency II Directive on insurance sector prudential regulation.
Message — The organization requests including competitiveness in Solvency II objectives, removing single market barriers, and ensuring proportionate application without stigmatizing cross-border business. They want refined group supervision and reduced reporting burden, plus technical adjustments to risk margin and calibration parameters.1234
Why — This would reduce regulatory burden and enhance their global competitiveness as insurers.567
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Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)

9 Sept 2021 · Insurance Ireland explained their position as regards the revision of Solvency II. The Commission representative took note and gave an update on the timing and process of the review.

Insurance Ireland warns against one-size-fits-all EU retail investment rules

18 May 2021
Topic — EU strategy to develop retail investments and enhance capital market participation.
Message — Insurance Ireland requests a differentiated, product-based approach rather than uniform rules for all financial products. They argue insurance-based investment products require special treatment because they protect against biometric risks while enabling savings. They also call for PRIIPs regulation to be overhauled and for increased focus on financial literacy.1234
Why — This would allow insurers to avoid burdensome comparability requirements that undermine their products' unique features.56
Impact — Consumers lose clearer comparisons between different investment products across the market.7
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Meeting with Mairead McGuinness (Commissioner)

24 Mar 2021 · Solvency 11

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

9 Nov 2020 · Introduction and discussion Solvency II review

Irish insurers urge lower capital requirements to boost EU growth

26 Aug 2020
Topic — This consultation reviews European insurance rules to ensure they remain fit for purpose.
Message — The group calls for reduced capital requirements and harmonized EU-wide supervision. They claim existing risk margin calculations are excessive and discourage long-term investment.123
Why — Reduced capital needs would unlock funds for growth and enhance global competitiveness.45
Impact — National authorities lose power if regulatory application is no longer left to discretion.6
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Response to Action Plan on the Capital Markets Union

3 Aug 2020

Insurance Ireland is the representative body of the Irish insurance industry. Ireland is the 5th biggest insurance market in the EU and the 2nd biggest market for reinsurance. Our members serve customers in more than 110 countries including 24 EU Member States. The integration of the EU single market is the key objective of our vision of an integrated, innovative and sustainable EU single market. We strongly support the Capital Markets Union (CMU) initiative. The CMU can have a significant impact on the EU’s economic recovery and the Green Deal. The CMU should aim at improving fair competition, enhancing the competitiveness of EU players at global level and, thereby, increasing product availability and consumer choice. With regards to its re-boost, we highlight the following aspects: 1. Optimising regulatory and supervisory convergence enhances fair competition, consumer protection and a regulatory level-playing field in the EU. In contrast to banks, with the Single Supervisory Mechanism, a more collaborative approach by National Competent Authorities (NCAs) is appropriate for insurance supervision. Such an approach does not need a single supervisor, but it requires a common interpretation of the single rulebook, consistent supervisory processes and an effective cooperation of NCAs. It is crucial that the European Insurance and Occupational Pensions Authority (EIOPA) has the right tools to steer this process. Improving information exchange and cooperation through digital supervisory platforms would be most important. 2. The freedom of capital and regulatory certainty are crucial aspects for the success of the CMU. Recent policies prohibiting the provision of dividends and similar payments significantly undermine these elements. Solvency II provides for all necessary powers for NCAs to assess and prohibit such payments on a case-by-case basis. Policies urging NCAs to diverge from the regulatory provisions are damaging the reliability of the EU regulatory framework. In cases, where cross-border intra-group transactions were prohibited, the freedom of capital is ultimately harmed. We believe that any political decision which interferes with the fundamental freedoms and the mandate of EU legislation should require a transparent and timely involvement of co-legislators. 3. Capital requirements must be reviewed to ensure the full investment and risk-taking capacity of insurers. The EU regulatory framework for insurers, Solvency II, proved to be robust, particularly during the recent capital market turbulences due to the Covid-19 crisis. But it also proved to be very prudent and inappropriately procyclical. Proposals to review the treatment of investments in equity and private debt are welcome. However, we suggest adjusting capital requirements holistically to avoid procyclicality, ensure insurers’ ability to invest long-term and mitigate risks. 4. We believe that the CMU should aim to enhance digital service provision and capital market governance. The use of technology can significantly enhance market access and ease of interaction/service for consumers. Capital market governance frameworks would benefit significantly from improved access to and exchange of data. For managing new and emerging risks (e.g. cyber) and for compliance purposes (e.g. sustainable finance) creating a European Single Access Point (ESAP) to data would be important for insurers. 5. Retirement savings are a central element for consumer participation in capital markets. Increasing the attractiveness of pension savings and the opportunities the new Pan-European Personal Pension Product (PEPP) can offer should be fully embraced. The efficiency and effectiveness of pension regimes should be strengthened, e.g. through auto-enrolment and basic pension products, like the PEPP. In addition to our position, we also support the position expressed by Insurance Europe.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

5 Jun 2020 · Digitalisation of the insurance industry (cybersecurity issues, digital skills, digitalisation of processes and client interfaces, data sharing, level playing field of regulatory requirements).

Meeting with Axel Voss (Member of the European Parliament)

20 May 2020 · Artificial Intelligence

Meeting with John Berrigan (Director-General Financial Stability, Financial Services and Capital Markets Union)

18 Feb 2020 · Sustainable Finance Agenda, Solvency II review and disclosure in retail products.

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

16 Oct 2019 · Fintech

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

20 May 2019 · Solvency II

Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

22 Jan 2019 · Brexit, Solvency II, PRIIPs

Insurance Ireland urges lower capital costs for long-term insurers

7 Dec 2018
Topic — The European Union is reviewing capital requirement rules for insurance and reinsurance companies.
Message — The organization requests lower financial safety requirements and more realistic calculation methods. They also advocate for simpler regulations for smaller firms to reduce administrative costs.12
Why — These changes would allow insurers to free up funds and lower customer premiums.3
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

26 Sept 2018 · Solvency II - Brexit

Response to REFIT review of the Motor Insurance Directive

24 Jul 2018

Insurance Ireland submission to the European Commission – Feedback on the Review of the Motor Insurance Directive is in the attached PDF.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

15 May 2018 · Solvency II, PEPP, ESAs review, Brexit, freedom to provide services

Response to REFIT review of the Motor Insurance Directive

21 Aug 2017

COMMENTS OF INSURANCE IRELAND AND THE MOTOR INSURERS’ BUREAU OF IRELAND ON THE EC INCEPTION IMPACT ASSESSMENT ON THE REFIT REVIEW OF THE MOTOR INSURANCE DIRECTIVE Insurance Ireland(II) and the Motor Insurers’ Bureau of Ireland(MIBI) welcome the REFIT Review of the Motor Insurance Directive(MID). We believe that the MID has worked well in terms of protecting road users across the EU. Our specific comments at this stage on the Inception Impact Assessment are as follows: Guarantee funds and the protection of victims in the case of insolvencies We absolutely believe that victims should be compensated and appropriate protections should be in place. In Ireland, the Insurance Compensation Fund (ICF) provides compensation to policyholders, and in turn their accident victims, in respect of insolvent non-life insurance companies who have been authorised by the Central Bank of Ireland, and to Irish customers of European insurers (who have been authorised in another EU member state) in respect of risks in the State (Ireland). In its capacity as the Motor Guarantee Fund in Ireland, the Motor Insurers’ Bureau of Ireland (MIBI), compensates victims of uninsured and untraced drivers. MIBI has no liability in instances of insolvency. Currently there is a limitation in coverage as, in the event of a liquidation, ICF compensation is capped at the lower of 65% of the sum due to the policyholder or €825,000. This may lead to a shortfall if the company in liquidation does not have sufficient assets. However, the Irish Government has recognised this issue and has a bill, General Scheme of the Insurance (Amendment) Bill 2017, working its way through the Oireachtas (the Irish parliament) that intends to increase compensation for motor accident victims in the case of an insolvency to 100%. We are supportive of this bill and believe it will protect victims. Scope of MID / “Vnuk” We support the Insurance Europe and the Council of Bureaux joint position paper of 11/8/17 that recommends the adoption of ‘option 3’ set out in the previous IIA on this topic, i.e. the scope of the MID should relate only to accidents caused by motor vehicles in the context of traffic. MIBI and II are particularly concerned that 1) we will see a significant increase in fraudulent claims staged in private land that cannot be readily investigated by Compensation Bodies/Insurers/Law Enforcement, 2) Gardaí (police) enforcement to reduce uninsured driving will be undermined (as many vehicles without identifying license plates and/or kept on private land would come into scope as requiring mandatory insurance) , 3) the impact on motor sports participants and attendees will be disproportionate, and 4) that accident victims in a workplace will be confused as to their route to compensation (there should be no difference in workplace compensation whether a victim was injured by a stationary machine or mobile vehicle). Minimum amounts of cover We note that the evaluation will look at the adequacy of the minimum amounts of cover laid down in the Directive, which must be provided by a motor insurance third party liability policy. Irish road traffic legislation does not specify a minimum amount of cover for personal injury claims and we believe the current property amount laid down by the MID is sufficient. II and MIBI look forward to responding to the EC Consultation Document on the REFIT Review in due course. David Fitzgerald, CEO, MIBI and Michael Horan, Non-Life Insurance Manager, Insurance Ireland 21 August 2017
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Response to DA on conduct of business rules for the distribution of insurance-based investment products

14 Aug 2017

1. Complex Products As currently drafted, one could interpret Article 16 could to mean that only products that offer some form of capital guarantee can be considered ‘non-complex’ under IDD . Based on the wording in the Directive and the preamble of the draft IBIPs Regulation, We do not believe this is the intention of the legislation. We suggest that Article 16 is amended to state that it is ‘Without prejudice to what can be considered non-complex for the purpose of Article 30 3 (a) (i) of Directive (EU) 2016/97’ namely: Insurance ‘contracts which only provide investment exposure to the financial instruments deemed non-complex’ under MIFID II Directive and ‘do not incorporate a structure which makes it difficult for the customer to understand the risks involved’ 2. Periodic Advice Article 14(4) of the draft IBIPs Regulation states that, at a minimum, advisers providing the periodic assessment of suitability should do so annually or more frequently depending on the nature of the product and/or customer. The regulations as set out that this has to be done annually, is onerous considering the nature of insurance based investment products. We would suggest Article 14(4) should refer to periodic assessment of suitability with frequency to be determined depending on the nature of the product and/or customer rather than imposing an annual requirement. 3. Information to be obtained from Customer Article 17(1) (c ) requires that all insurance intermediaries and Insurance undertakings obtain from their customer’s or potential customers information about their level of education. It is our belief that this will be challenging to obtain and evidence and in addition may some customers may find this request offensive. We suggest removing the explicit reference to level of education from Article 17 (1)(c ) or reword to include knowledge and experience to be consistent with other articles of the directive. 4. Periodic Report We would welcome further clarity as to the content/format expected to be included in Periodic Reports under Article 18. The current references to “Services provided’ is unclear as what is required to include in such reports and could as worded refer to advice provided as well as transactional information. Is the intention of Article 18 to provide the customer with details of transactions, costs and value of each underlying investment without providing a report of any advice provided in the period? 5. Retention of Records Article 19(2)(d), We would welcome clarity on what is defined by “changes to the underlying investment assets “ It is our understanding that this refers to any change of funds/products held by a customer (i.e. a fund switch) rather than the constituent assets of the funds themselves changing. The constituent assets of a fund may change periodically (a) without having any significant changes to the risk portfolio of the fund or (b) through a de-risking strategy.
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