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International Credit Insurance & Surety Association

ICISA

The object of the Association is to study questions relating to Credit Insurance and Surety, to provide opportunities for Members' employees to acquire knowledge of the theory and practice of credit insurance and surety underwriting, to represent the Members’ interests and to initiate means whereby the common action of the Members can be facilitated in order to develop their mutual relations in the interest of their national and the international economy, in the interest of their insured and in their own interest.

Lobbying Activity

Meeting with Almoro Rubin De Cervin (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Afore Consulting and

3 Dec 2025 · Credit insurance

Response to 28th regime – a single harmonized set of rules for innovative companies throughout the EU

30 Sept 2025

ICISA is pleased to have the opportunity to contribute to discussions on ways to support innovation and growth among Start-ups and Scale-ups. As a sector which facilitates trade and investment through trade credit insurance, credit and political risk insurance, and surety bonds, our members support this important segment in their efforts to grow and trade throughout the EU and beyond. Dealing with multiple regimes can be a complex challenge for many businesses, but particular those within this segment. To ensure success, this initiative must ensure clarity in legislation between national regimes and the 28th regime. We believe in particular, that clarity is essential on issues relating to insolvency proceedings, subrogation rights for insurers, and related processes. Achieving this objective can encourage financial service providers to engage further with this segment, further unlocking protection and financing to stimulate growth and innovation. More detailed feedback can be seen in our attached response.
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Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

4 Sept 2025

With respect to the proposed amendments, we highlight three points of particular relevance to credit and surety. The new requirements in Article 311 (paragraphs 6 and 8) to report on financing transactions entered directly or indirectly are unclear and could be read as capturing trade credit insurance (or surety) of receivables from factoring or supply chain finance. ICISAs understanding is that these are not in scope of Article 311 reporting. Similarly, ICISA understands that the reference to liquidity risk exposure in Article 311 does not encompass trade credit insurance (or surety) coverages of receivables from factoring or supply chain finance, as the provision is intended to capture transactions which fall outside of the core business of insuring an uncertain future event. To avoid divergent supervisory interpretations, we recommend explicit clarification of Article 311 to specify which activities and exposures are in scope. In particular, we request that this makes clear that neither the scope of reporting nor the reference to liquidity risk exposure extends to trade credit insurance, surety, the insurance of receivables linked to factoring or supply chain finance, or related activities. We also note the recalibration of the Minimum Capital Requirement factors for credit and surety, with the factor for technical provisions reduced to 16.0% and the factor for premiums increased to 17.7%. While the objective to rebalance between provisions and premiums is recognized, further dialogue would help ensure that the calibration remains proportionate to the actual risk profile of the business. Finally, we welcome the recognition of public counter-guarantees as eligible credit risk mitigation under the spread risk sub-module. Overall, we believe that clarifying the scope of Article 311 and ensuring proportionate calibration of the MCR will strengthen consistency, preserve the risk-based nature of the framework, and allow insurers to continue supporting trade, investment, and the European economy.
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque)

30 Apr 2025 · Introductory meeting

Response to EU Start-up and Scale-up Strategy

14 Mar 2025

We welcome the Start-up & Scale-up Strategy and its focus on improving access to finance. To enhance its effectiveness, the strategy should acknowledge existing financial instruments such as Trade Credit Insurance (TCI) and Surety Bonds, which play a crucial role in de-risking transactions, unlocking financing, and enabling business expansion. TCI is a commercial insurance line which protects businesses against the risk of non-payment of receivables by commercial trading partners. Non-payment of invoices due to insolvency can have a domino effect through supply chains with one instance of non-payment leading to others further down the line. With TCI in place, that domino effect is halted, and supply chains made more resilient. TCI improve access to working capital and fosters cross-border trade. Financial Institutions also value the protection TCI provides by mitigating the credit risk of their clients, thus enabling financing at greater volumes or on better terms. Surety Bonds are a related specialty insurance product which provide protection against the non-performance of contractual obligations. These can be provided for a range of activities, including construction contracting, judicial bonds, or customs bonds. Surety provides the financial security needed for contractual commitments, helping scale-ups compete more effectively when bidding for larger projects and public tenders. These instruments are already well-established in the private sector and could complement new policy measures without duplicating existing solutions. We encourage the Commission to integrate these market-driven tools into the strategy to support business growth and financial resilience. We remain available to provide further information about the TCI and Surety markets, and how they can support the Commission in meetings its objectives for start-ups and scale-ups.
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Meeting with Marie-Hélène Pradines (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

4 Feb 2025 · Late Payment

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

5 Dec 2023 · introductory meeting, Solvency II review

Response to Revision of EU rules on late payments (Late Payments Directive)

7 Nov 2023

The International Credit Insurance and Surety Association (ICISA) is the global trade association for trade credit insurers, sureties and their reinsurers. Trade credit insurance is utilised by business of all sizes and across all sectors as a means to mitigate the significant risks they face from non-payment. ICISA agrees with the Commissions assessment that late payments have a significant negative impact on businesses. We also concur that this burden is disproportionately faced by SMEs and that reducing the incidence of late payment will have a positive impact on the business environment within the EU. However, it is our view that proposals must be amended to avoid unintended negative consequences. We refer you to our attached position paper for details of our fuller response to the proposals.
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Meeting with Frances Fitzgerald (Member of the European Parliament)

9 Feb 2023 · ICISA

Meeting with Esther De Lange (Member of the European Parliament)

8 Feb 2023 · CRR/CRD - APA

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

21 Nov 2022 · Export credit guarantees

Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

21 Feb 2022

The International Credit Insurance and Surety Association is the global trade association representing the leading providers of trade credit insurance and surety internationally. Our members provide services worldwide, but given the prominence of European markets, the majority of our trade credit insurance members are located within the EU and regulated under the Solvency II framework. We are pleased to provide our response to the proposals on banking prudential requirements and their alignement to international standards. Specifically, we address our comments to those elements which are directed towards the treatment of credit insurance within that framework. Our comments are provided in the attached document.
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Meeting with Markus Ferber (Member of the European Parliament, Rapporteur)

25 Jan 2022 · Insurance Regulation: Solvency II

Response to Amendments to the implementing rules on solvency applicable to insurers

6 Dec 2018

The members of ICISA, the International Credit Insurance & Surety Association, represent roughly 95% of the world’s private credit insurance business and a substantial part of the surety insurance business with over € 2 300bn of trade receivables coverage and billions of euros worth of construction, services and infrastructure guaranteed in 2017. Our mission is to secure the transactions of SMEs, midsized companies and major corporate groups. In the Draft delegated regulation amending and correcting Delegated Regulation (EU) 2015/35, the European Commission proposes the following review regarding the volatility applicable to the “credit & suretyship (C&S)” line of business (LoB): (i) to increase the parameter applicable to premium risk (from 12% to 19%) and (ii) to decrease the parameter applicable to reserve risk (from 19% to 17.2%). ICISA, the International Credit Insurance & Surety Association, considers that, as such, it does not properly achieve the objectives stated in the request dated 18 July 2016 to EIOPA: - the achievement of the “removal of unintended technical consistencies” is questionable, considering the weaknesses in the quantitative study (lack of representativeness) and in the impact assessment which have been underlined by the ECON committee in its letter dated 18 September 2018; - although it is noted that the European Commission has proposed to postpone the application of this recalibration to 2020, for specialized credit and suretyship insurers the impact of this proposal is a material decrease in SCR coverage ratio, by 10 to 20 points according to the input and calculations of our members. Therefore, this review could lead to an increase in the cost of credit and suretyship insurance to compensate for the material decrease in the SCR coverage ratio, and as such would conflict with the CMU objective of removing unjustified constraint to financing and supporting the wider economy. Thus, ICISA supports the maintaining of the current regulation regarding the calibration of the C&S line of business as long as a more convincing study is not performed, for example in the context of the 2020 SII review. ICISA is strongly committed to intensifying its participation in data collection and analysis to help EIOPA in its implementation of such study. For more background, please see the attached file.
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Response to Public export subsidies (short-term export credit insurance) – extension of EU rules

12 Nov 2018

The members of the International Credit Insurance & Surety Association (ICISA) have no objection against the proposed extension. We would request that additional criteria are considered after the extension period, taking into account the effects of Insurance Premium Tax on risks insured by the private market versus risks insured by public export credit agencies, to ensure market rates and a level playing field for exporters.
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