Polska Izba Ubezpieczeń
PIU
PIU represents insurance and reinsurance establishments -members of the Chamber- before public authorities and undertakes any activity to protect their interests.
ID: 025548450390-70
Lobbying Activity
Response to Digital package – digital omnibus
14 Oct 2025
The Polish Chamber of Insurance (PIU) appreciates the European Commissions efforts to streamline and simplify the regulatory framework in the digital sphere, which is an important step towards enhancing innovation and competitiveness across the European Union. In this context, PIU supports the position presented by Insurance Europe, supplemented with the following comments. 1. Artificial Intelligence Act (AI Act) PIU advocates for a more proportionate approach in the AI Act by narrowing the scope of prohibitions, especially in areas that may unduly impact the insurance sector. Furthermore, PIU recommends reducing the level of administrative fines for potential breaches regulated under the AI Act, to ensure proportionality and prevent unintended negative impacts on market stability and innovation. 2. Financial Data Access (FIDA) Regulation PIU calls for the withdrawal of the draft FIDA Regulation, emphasizing that, in light of the current geopolitical and cybersecurity challenges, the European Union should focus its efforts on strengthening the protection of highly sensitive data, particularly citizens financial information. PIU stresses that regulatory initiatives should enhance data security rather than promote mechanisms facilitating the exchange of such data, including with third countries. This position is further based on the following fundamental concerns: High implementation costs and operational burdens for insurance undertakings; Lack of clearly defined benefits for consumers; Absence of practical examples enabling an assessment of the actual risks posed by such a broad regulatory framework; Diversion of resources from innovation and product development toward the implementation of complex data-sharing mechanisms; Reduced competitiveness of the European insurance sector, limiting its ability to introduce new products and services; Creation of additional operational and security risks, contrary to the EUs declared objectives of regulatory simplification and enhancing market competitiveness.
Read full response5 Sept 2025
The Polish Chamber of Insurance (PIU) is a statutory organization of insurance industry self-government. PIU was established in 1990 and represents all insurance companies operating in Poland. PIU promotes good market practices and supports insurers initiatives. PIU increases public awareness about insurance. PIU supports both national and EU legislators in shaping insurance law and conducts a multilateral dialogue for the development of the insurance sector. PIU welcomes the European Commissions work on the Solvency II Delegated Regulation, particularly its efforts to gather feedback on proposed changes to the technical rules governing the valuation of insurers liabilities, the calculation of solvency requirements, reporting and disclosure obligations, group supervision, and other related areas, as part of the broader initiative to improve the functioning of the EU financial system under the Savings and Investments Union (SIU). PIU supports the position prepared by Insurance Europe for the purpose of this consultation, in which it was actively involved; however, it would like to present a more detailed and independent position regarding foreseeable dividends and natural catastrophe risk in the standard formula. Detailed remarks concerning these areas have been presented in the attached position paper.
Read full responseResponse to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector
21 Jul 2025
The Polish Chamber of Insurance (PIU) is a statutory self-governing organization of the insurance sector, established in 1990. It represents all insurers operating in Poland, promotes sound market practices, and fosters public awareness of insurance. PIU engages in dialogue with both national and EU legislators, contributing to the development of insurance law and policy. PIU welcomes the European Commissions initiative to enhance the efficiency of the EU pension framework. In Poland, key challenges include low participation in voluntary pension schemes, limited public trust, and weak integration between pension pillars. A coordinated EU-level approachwhile respecting national differencescan significantly improve retirement outcomes across Member States. Poland is experiencing a widening pension gap, the result of demographic, economic, and systemic factors. The public pension system is based on a pay-as-you-go model, which is increasingly unsustainable in the face of one of the fastest-aging populations in the EU. The ratio of active workers to retirees continues to fall, straining the system's viability. The adequacy of future pensions is a major concern. Currently, retirees face a steep decline in income upon retirementaround 50% of their final salary. For those retiring in the 2030s and beyond, this situation will deteriorate further. People born between 1970 and 1975 may see income fall by 66%, while individuals retiring after 2045 could face up to a 75% drop in income. These projections raise serious concerns about old-age poverty and emphasize the urgent need for reforms and greater participation in supplementary pension schemes. EUROPOP2019 projections estimate that Polands population will decline by approximately 7 million by 2070, mainly due to falling fertility rates. The total fertility rate (TFR) decreased from 2.06 in 1990 to 1.36 in 2019. Even with a projected increase to 1.65 by 2070, it will remain below the natural replacement rate. Moreover, the old-age dependency ratio (the ratio of people aged 65+ to those aged 1564) is expected to rise from 29% in 2019 to 68% in 2070. This demographic shift will significantly burden the pension system, as fewer workers will be available to support a growing number of retirees. The imbalance threatens the sustainability of the pay-as-you-go model and underscores the importance of developing alternative pension mechanisms and boosting long-term savings. The full PIU position in response to this call for evidence is attached.
Read full responseResponse to Recommendation on savings and investment accounts
7 Jul 2025
The Polish Chamber of Insurance (PIU) welcomes the European Commissions initiative to strengthen the Savings and Investment Union (SIU) and promote long-term saving and investment among European citizens. However, we believe that the current approach to the proposed Savings and Investment Account (SIA) risks excluding important players and proven investment solutionsparticularly life insurance products. The detailed position of the PIU on the Recommendation on savings and investment accounts is attached.
Read full responseResponse to Revision of EU rules on sustainable finance disclosure
30 May 2025
The Polish Chamber of Insurance (PIU) would like to thank you for the opportunity to express its position as part of the ongoing call for advice on the revision of the SFDR. PIUs position paper submitted in the context of this consultation has been included in the attachment.
Read full responseMeeting with Maria Luís Albuquerque (Commissioner) and
6 Mar 2025 · • SIU • Simplification and competitiveness • Solvency II
Response to Claims history statement template for motor insurance
23 Feb 2024
Polish Chamber of Insurance (PIU) from the beginning of its work on the review of Directive (EU) 2021/2118 of the European Parliament and of the Council of 24 November 2021 amending Directive 2009/103/EC relating to insurance against civil liability in respect of the use of motor vehicles, and the enforcement of the obligation to insure against such liability (MID), indicated that standardization of the claims history statement certificate (CHS) was a good solution. However, it is important that the scope of information mandatorily to be included in the CHS is not too broad. Article 16 of the MID defines the scope of information that should be included in the CHS, and the European Commission's proposal should not expand this scope. Introducing their broader scope would lead to significant administrative and It work for insurance companies and amendments to current legislation. Detailed PIU comments on the CHS template have been included in the attachment.
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
4 Dec 2023
Polish Chamber of Insurance (PIU) supports proposed solutions aimed at systematizing requirements related to circular system of vehicle design stage and managing wrecks. We certainly endorse the goal of the proposal, which is to improve the quality of vehicles in the secondary market, encourage recycling, and achieve the most effective management of wrecks. Regardless of the environmental benefits, the proposal will have significant economic consequences for Polish insurance companies and their clients, especially considering the specific characteristics of the Polish market (an aging fleet of vehicles and currently applicable procedures for claims handling of total damage and managing wrecks after total damage, as well as customers' habits of repairing vehicles after total damage). After reviewing the content of the proposal, we have identified numerous problematic issues that we would like to bring to attention of the European Comission. These covers i. e.: lack of clarity of the proposal; unclear definition of ELVs; lack of proper consideration of the issues related to MTPL (Motor Third Party Liability) insurance and the claims settlement procedures; repairability criteria (including economic irreparability criterion); and repairability of batteries. Our position has been further elaborated in the attached postion paper.
Read full responseResponse to Open finance framework
1 Nov 2023
FIDA regulation will have a significant impact on the Polish insurance companies and insurance intermediaries and their relationships with the immediate economic environment, including insurance company clients, entities cooperating with insurance companies, and potential future insurance company competitors. The opening of the insurance sector to financial data exchange concerning products used by insurance company clients presents certain opportunities for both insurance company clients and insurance companies. However, it is essential to emphasize that the shape of the future regulation raises many doubts and risks, not only for insurance companies but also for insurance company clients. The FIDA proposal however presents risks for insurance companies and their clients. The list of these risks is significantly longer than the list of potential opportunities and benefits. Please find full feedback attached.
Read full responseMeeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski)
13 Sept 2023 · Retail Investment Strategy (RIS); EC legislative acts concerning the insurance sector in the context of agriculture and the green transformation; Report by PIU on climate change and its impact on the insurance sector
Response to Retail Investment Package
28 Aug 2023
The Polish Chamber of Insurance (PIU) is a statutory organization of industry self-government. It was established in 1990 and represents all insurance companies operating in Poland. PIU is grateful to the European Commission for the opportunity to present comments on the proposal of the Retail Investment Strategy (RIS). PIU supports the RIS goals of enhancing retail investor participation in the capital markets union and safeguarding against unfair practices in the financial market. However, many proposals within the RIS package raise serious concerns for the Polish insurance market. These proposals do not take into account the specificities of the local financial markets and could complicate the distribution of Insurance-Based Investment Products (IBIPs) for both insurance distributors and customers. The solutions proposed by the RIS package might seriously hinder offering of insurance products with savings and investment characteristics: 1. Ban on Inducements when no advice is provided: The ban on commission for IBIPs distribution without advice could hinder product distribution and contradict the RIS goals, causing unintended consequences in the Polish market. PIU suggests amending Article 29a of the IDD Directive to allow commission for IBIPs being sold without advice, considering the unique market conditions in particular member states. 2. Customer best interest assessment: The amendments introduced by RIS to Article 29b of the IDD Directive regarding best interest of customer assessment might be extremally difficult exercise for insurance companies and tied agents, limiting their ability to recommend suitable products. New proposal could lead to choosing the cheapest insurance product by the customers rather than products which are most suitable for them. 3. Value for Money (ESAs Benchmarks): Limiting cost and performance levels to pan-European benchmarks might overlook specific market characteristics, impacting the competitiveness of the Polish insurance market. Local financial supervisory authorities could better develop indicators for each market. 4. Providing personalized information to customers: While acknowledging the positive move towards electronic communication with customers, PIU notes that some of the proposed solutions increase complexity and overwhelm customers with technical information, potentially discouraging retail investors from investing in IBIPs. 5. Changes to PRIIPs KID: PIU supports digitalization of the KID. However, the option to personalize the PRIIPs KID is likely to lead to inconsistency and additional administrative burdens for insurance companies and intermediaries. 6. New obligations regarding marketing practices: The proposed RIS regulations concerning marketing practices could create unjustified burden for insurance market with no added value for the customers. Pan-European marketing practices standardization could not take into account local market specifics and consumer financial literacy levels. 7. New obligations regarding customer needs assessment: PIU underlines vagueness in requirements for assessing customer needs before binding them to contracts, which could introduce additional challenges and cooling-off periods in the distribution of insurance products. 8. Unrealistic implementation deadline and lack of details to be developed on level 2: PIU finds the implementation deadline unrealistic and worries about the lack of details in the current RIS level 1 proposal - which are to be developed within level 2 regulations by ESAs on the basis of the COM mandates. Insurance undertakings and intermediaries need at least 18 months from the moment they become aware of all the level 1 and 2 requirements to properly adjust to them. Attached, we also provide a detailed analysis that elaborates on the aforementioned problematic points raised by PIU.
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