Reinsurance Advisory Board
RAB
Insurance Europe’s Reinsurance Advisory Board (RAB) is a specialist representative body for the European reinsurance industry.
ID: 341051518380-63
Lobbying Activity
5 Sept 2025
To maintain Europes leadership in global reinsurance, SII must remain risk-based and free of non-economic barriers. We urge the Commission to consider the following amendments (order does not reflect an order of priority). 1. Risk-mitigation techniques: Avoid impacting 99% of reinsurance contracts with an unworkable demonstration of transfer of risk in Articles 210 to 212 for both proportional and non-proportional (NP) reinsurance. For instance, it is unclear whether NATCAT NP reinsurance for motor insurance would qualify as RMT under the proposed changes. These substantial changes are the negation of a functioning and competitive EU reinsurance market. in contradiction with Recital 18s stated objective to improve the recognition of NP reinsurance. A proper impact assessment is needed before any change is made. 2. ADCs: Improving the treatment of NP reinsurance in the standard formula is a topic under discussion since the 2018 Solvency II review. The proposal put forward could work, subject to some changes. We kindly call on the Commission to consider the technical arguments and examples put forward by the RAB on solutions to current challenges (see Annex). 3. Group minimum SCR: Exercise the empowerment given in the Level 1 to remove the double-counting of third-country risks in the group minimum SCR, which affects EU-based international groups due to their global presence and vertical structure. Clarifying this point is essential to ensure European groups can compete and grow globally, whether organically or through acquisitions, as the non-economic double-counting of third-country risks in the Group minimum SCR is not part of any other regime in the world and would unfairly disadvantage EU-based groups. 4. Risk margin: Eliminate the 50% floor to the new calibration of the risk margin, as it unduly restricts the effectiveness of the lambda in supporting long-term guaranteesthe very objective of the review. While falling short of a justified level of 92.5%, the introduction of a lambda at 96% is welcome, but the risk margin will remain larger than in other jurisdictions, leading to a competitive disadvantage for European insurers. 5. Internal models: Maintain the recognition of contingent capital instruments in internal models. This proven capital shield, used to protect reinsurers against e.g. extreme NATCAT losses, can be properly reflected in internal models. Address the ambiguity in terms of the standard formula estimate to be provided by internal model users. Clarify that the format, content, and reporting channel should be agreed directly between the NCA and the undertaking, independently from the RSR and SII QRTs processes by default unless otherwise requested by the supervisor. 6. EPIFP: Delete the reference to EPIFP in the group capital availability assessment in Article 330. The EPIFP is an integral component of the reconciliation reserve and should be treated like other own funds included herein, i.e. as always available at group level without separate availability assessments. Changing the treatment of EPIFP would eliminate a key incentive to provide long-term guarantees. 7. VA: Groups should be permitted the option to apply the same credit spread sensitivity ratio (CSSR), per currency, for entities of a subgroup or group, calculated based on the subgroups or groups asset and liability portfolios. 8. Reporting: The ORSA covers sustainability risks, if material, and measures to address these risks, and thereby should include the sustainability risk plan reporting. No other reports, such as the proposed SFCR requirement, should duplicate these reporting requirements. RSR: Exceptions for reporting should consider complexity criteria to assess the overall risk profile. The three-year frequency would be aligned with the European Commissions strategy to reduce reporting burdens. Further detailed responses to the ECs proposals are included in the Annex below.
Read full responseMeeting with Yann Germaine (Acting Head of Unit Financial Stability, Financial Services and Capital Markets Union)
23 Jun 2025 · Exchange of views on the reinsurance-specific aspects of the IRRD
Meeting with Maria Luís Albuquerque (Commissioner) and
4 Jun 2025 · Exchange on market developments.
Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
26 Mar 2025
Insurance Europe's Reinsurance Advisory Board (RAB) welcomes the European Commission's (EC) initiative to amend the Taxonomy Delegated Acts (DA) to make reporting simpler and more cost-effective for companies. The RAB welcomes simplifications of the templates for (re)insurance undertakings and the fact that these reductions make it more reasonable for the users and those preparing the reports. However, the reduction in number of data points does not necessarily translate in the same amount of reduction in efforts. The data would still need to be collected even if less segmentation in data is required. The RAB wishes to highlight the following suggestions to improve the current proposal: 1.Reinstatement of text previously included on the 'pro-rata approach'. 2.Clarification on nuclear and gas reporting. 3.Clarification on a 10% threshold option. 4.Earlier review of the technical screening criteria (TSC). Potential improvements: 1.The pro-rata approach: The RAB believes the amendments to the disclosure DA include the deletion of important text in Annex X 'Templates for KPIs of insurance and reinsurance undertakings' (see Annex V of this consultation amending Annex X), potentially by mistake as no justifications are being given by the European Commission. We draw your attention to the fact that this text appears in the PDF version on the EURLEX website but is cut off in the html version, an unfortunate situation which may be the source of the likely mistake in the consulted proposal. The deleted text relates to the pro-rata approach. The RAB believes the following text should be restated (mutatis mutandis considering the new template): "Where a reinsurance activities of an undertaking comprises products applying at the level of a portfolio of underlying direct insurance products and the undertaking assesses the compliance of the activity with the technical screening criteria and the do no significant harm criteria for a proportion of the reinsurance activitys underlying products pursuant to Climate Delegated Act, Annex II, point 10.2, paragraph 2.3 (pro-rata approach), the pro-rata approach should be applied consistently for the information reported in all columns of row A.1.2." The possibility to use the pro rata approach, allowed for meeting the TSC, is necessary to avoid reinsurers systematically failing the 'Do no significant harm' (DNSH) test. As currently worded, reinsurers can't meet the requirement if just one underlying policy among thousands in a typical treaty fails the DNSH test. The EC previously included the text above as a fix to the Climate DA. Removing this text is not serving the purpose of simplifying the Taxonomy. 2. Nuclear and gas reporting: The RAB supports the elimination of the separate gas and nuclear templates but believes that the Taxonomy DA should clarify more clearly that nuclear and gas reporting won't be required for underwriting activities. This could be clarified in a recital of the amending DA. 3.10% threshold option: The RAB welcomes the EC's introduction of a 10% threshold option. It would be useful to clarify that for reinsurers, this threshold applies to both 10% of the assets and 10% of the premiums on both the numerator and denominator. 4.TSC review timing: The RAB welcomes the EC's intent to review the TSC. However, the RAB would suggest an earlier review to better reflect the contribution of reinsurers to climate adaption as soon as possible. Insurance Europe's Reinsurance Advisory Board (RAB) is a specialist representative body for the European reinsurance industry. It is represented at chairman and chief executive officer (CEO) level by the seven largest European reinsurance firms: Gen Re, Hannover Re, Lloyd's, Munich Re, PartnerRe, SCOR and Swiss Re, with Insurance Europe providing the secretariat.
Read full responseMeeting with Mairead McGuinness (Commissioner) and
22 Mar 2022 · Solvency II and sustainable finance.
Meeting with Tommy De Temmerman (Cabinet of Commissioner Mairead Mcguinness)
1 Feb 2022 · Preparatory meeting with RAB-Solvency II and sustainable finance.
Response to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)
12 Jan 2022
The Insurance Europe Reinsurance Advisory Board (RAB) welcomes the opportunity to contribute to the European Commission’s consultation on the proposal for an Insurance Recovery and Resolution Directive (IRRD).
The Commission’s proposals in areas such as recovery and resolution allow for what the RAB strongly believes would be an unjustified and significant increase in regulatory requirements and operational and reporting burdens. In the RAB’s view, one of the key drivers of all these challenges is inappropriate recognition of the specific nature of reinsurance.
The RAB believes that, in the context of the IRRD the scope of recovery and resolution should be aligned, the resolution should take a top-down approach at group level, and that specific, simplified obligations should be considered for reinsurers given the characteristics of reinsurance business. In addition, there is no justification for the blanket inclusion of all reinsurance groups in the resolution regime.
Reinsurance activity contributes to the overall resilience of the insurance market by pooling and diversifying risks across lines of business and geographies. It is wholly dissimilar to banking business and there is a lack of evidence of any exposure to bank run-like liquidity stresses or an impact on systemic risk:
- The potential failure of a reinsurer is very unlikely and has no direct impact on policyholders. The premiums ceded are still accounted for in the technical provisions of the cedant insurers, which meet their obligations to the beneficiaries.
-Regarding activity-based systemic risk, reinsurance is primarily about property, casualty and biometric risks. Those risks are not linked to the financial cycle and therefore traditional reinsurance activities are not subject to “bank runs” or the risk of fire sales.
- Regarding behaviour-based systemic risk, reinsurance activity covers long-tail risks in particular. This feature, combined with the fact that reinsurers are balance-sheet light compared to other financial institutions and their activity is not correlated to the financial cycle, means that they are not prone to herd behaviour.
- The fact that the reinsurance market is dominated by global players should be seen positively. This allows risks to be pooled and then diversified on a global scale, thus mitigating the impact of external shocks. In addition, the reinsurance market is highly competitive and therefore reinsurance portfolios are easily transferable and entities easily substitutable.
- Despite the importance of reinsurance in mitigating tail risks, the linkage between reinsurers and primary insurers should not be overstated. Indeed, just 5% of primary insurers’ written premiums are ceded globally to reinsurers.
- The interconnections between reinsurers are also low. Retrocessions account for only 13% of global reinsurance premiums and 0.6% of global primary insurers’ written premiums. Moreover, the retroceded premiums are still accounted for in the technical provisions of the cedant reinsurers such that retrocessions have no similarity with off-balance sheet securitisations.
As a result, the specific characteristics of the reinsurance business should be recognised.
Our full response can be found in the document attached.
Read full responseResponse to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)
12 Jan 2022
The Insurance Europe Reinsurance Advisory Board (RAB) welcomes the opportunity to contribute to the European Commission’s consultation on the Solvency II review proposal.
The RAB strongly supports the Solvency II regime and its risk-based approach. Solvency II is today the most advanced insurance regulatory regime in the world and it has passed the test of the COVID-19 crisis.
Over recent years, the RAB has actively contributed to the review of Solvency II by engaging with EIOPA and the European Commission. The review provides the opportunity to address the framework’s excessive capital burden and volatility and it should avoid increasing the already very high operational burden the regime places on European (re)insurers. The right set of changes can lay the groundwork for the European reinsurance sector to strengthen its competitiveness, to contribute to reducing protection gaps and to support a sustainable European recovery. These priorities fully align with the Commission’s objectives and there should be a common interest in delivering on them.
The RAB welcomes the Commission’s intention to better recognise some reinsurance covers and to reduce the level and volatility of the risk margin for long-term business. The proposed changes are technically justified and bring more insurance and investment capacity to the EU.
However, the Commission’s proposals in areas such as internal models (IM) allow for what the RAB strongly believes would be an unjustified and significant increase in regulatory requirements and operational and reporting burdens. In the RAB’s view, one of the key drivers of all these challenges is inappropriate recognition of the specific nature of reinsurance.
The RAB believes that the review needs to ensure the following:
- Standard formula (SF) reporting — which is not necessarily optimal for capturing all reinsurance risks and diversification between these risks appropriately — should not be required of reinsurers using an approved IM.
- Any changes made to risk mitigation techniques (RMT) must give fair recognitions to the SF. The RAB welcomes the progress made on the treatment of innovative forms of non-proportional loss-sharing between insurers and their reinsurers (adverse development covers or ADCs) but is concerned by the inclusion of inappropriate new “safeguards” announced in the EC Communication. The RAB urges the EC to base any modification of the delegated act in respect of such safeguards on the latest EIOPA opinion on the topic published in July 2021 rather than the EIOPA advice published in December 2020. EIOPA recognised in its final opinion on RMT that the new “commensurate” criterion would need to be defined by reference to a deviation of the risk profile of the company vis-à-vis the SF assumptions.
- The introduction of additional “early-intervention” measures to be applied before the breach of the SCR, during times of exceptional market-wide shocks or via the Insurance Recovery and Resolution Directive (IRRD), should be avoided and not go beyond international standards. These measures would undermine the credibility of the SCR, while imposing a disproportionate and unreasonable burden on European reinsurers compared to their global competitors.
- Changes to Solvency II reporting ITS, which EIOPA initially planned to make applicable for YE2022 closing, are both overly extensive and unnecessary. The RAB therefore welcomes EIOPA’s proposal to postpone the date of application by one year and to consider further postponements of more than one year for certain templates. In a timely manner, the enforcement of the amendments to the QRT-reporting should be aligned with the overall enforcement of the 2020 Review requirements to minimise the implementation burden.
Our full response can be found in the document attached.
Read full responseResponse to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information
2 Jun 2021
The Reinsurance Advisory Board (RAB) welcomes the possibility to comment on the European Commission (EC) proposal and suggests the following adjustments:
KPI for underwriting activities
The current KPI must be improved to provide a more realistic picture of the nature of reinsurance business and not result in misinformation.
Numerator
- Both the assessment of the technical criteria of the climate adaptation objective and of the do no significant harm principle (DNSH) should be done on a pro rata basis.
- In its current design, the numerator risks inadvertently excluding a large share of reinsurance business because the DNSH criteria do not fairly represent the sustainability ratio of reinsurers for business written on a portfolio basis (treaty business). The EC should clarify that the current template (column 11 of Annex X) does not apply as a Yes/No test to the taxonomy-aligned business in columns 3-4 on adaptation objective. In its current form, the DNSH test in the template may be interpreted as disqualifying all otherwise taxonomy-aligned treaty reinsurance business if just one underlying policy among thousands in a typical treaty fails the DNSH test.
- Failure to clarify this aspect may lead to a major inconsistency, ie a particular policy could be considered taxonomy-aligned by an insurer, but not aligned by the reinsurer when included in a treaty. To avoid this, the RAB suggests the following (see template in position paper):
•Deleting the DNSH columns 11, 13, 14, 15, 16 to 17, in line with the credit institutions’ templates and renaming column 6 as “Climate Change Adaptation Taxonomy-aligned premiums (passing the DNSH test)”. Column 6 should contain only premiums that meet both criteria of contributing to climate change adaptation & passing the DNSH test.
•Clarifying that the information provided in columns 3, 4, 19 and 6 is the outcome of both the technical criteria checks and the DNSH checks in combination and on a pro rata basis. To this effect, coherently with the Annex 2 of the Climate Delegated Act Chapter 10.1, the following sentence should be added under the template: “Regarding the assessment of DNSH (climate change mitigation), where a reinsurance product applies at the level of a portfolio of underlying products, a share of the reinsurance activity’s underlying products may include cession of insurance of the extraction, storage, transport or manufacture of fossil fuels or the cession of insurance of vehicles, property or other assets dedicated to such purposes. In that case, the reinsurer shall identify the share of reinsurance premiums that relate to those underlying products and use that information to exclude that share from the Taxonomy-aligned premiums in columns (3) and (4).”
Denominator
- The appropriate denominator should be the Taxonomy-eligible premiums, not the total premiums. The ratio of Taxonomy-aligned activities should reflect the progress being made in terms of contribution to adaptation:
•The denominator should have the same scope as the numerator. Like the numerator, it should only account for Taxonomy-eligible business. Absent of this, the ratio of reinsurers would be badly misrepresented. The part of the reinsurance business that is not Taxonomy-eligible should be reported separately as done for non-financial undertakings.
•The amount/share of business with non-EU entities or non-NFRD/CSRD entities should be excluded from the scope of the climate adaptation ratio, as done for the numerator. Exposures for which Taxonomy-alignment data is unavailable should be excluded from the denominator.
Implementation timeline & data flow sequencing
The RAB welcomes the proposal for a phased in timeline for application. For a practicable timeline and data flow sequencing, the regulation should clarify that reinsurers may use the latest available data to identify premiums as well as proxies or estimates, which are particularly relevant for treaty business, as highlighted in EIOPA’s advice, p.9.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
The RAB welcomes the opportunity to provide comments to the EC consultation on the technical screening criteria for the Taxonomy Regulation. The RAB comments focus on the Annex II, regarding criteria for reinsurance as activity substantially contributing to climate change adaptation.
In the general context of the regulation, it appears that the proposed criteria are limited to the coverage of risks stemming from climate-related perils set out in Appendix A ceded by the insurer to the reinsurer. In this respect, the RAB would like to point out that:
the classification of climate-related hazards in Appendix A should not be considered as an exhaustive list. The list should be reviewed periodically to ensure it is updated with all relevant weather-related perils and considers the occurrence of potential new hazards.
lines of business and segments not directly in scope of climate-related perils (eg life and health) could also be classified as “environmentally sustainable” provided they substantially contribute to climate change adaptation or cover sustainability-related risks.
beyond non-life and reinsurance activities, more insurance-related activities could also be considered as sustainable according to the EU environmental taxonomy, based on their capacity to provide adaptation to climate change risks. For example, the so-called catastrophe bonds and related classes, such as Insurance Linked Securities (ILS) could automatically be considered eligible activities under the taxonomy. By channelling capacity from capital markets, ILS enable the capacity of the (re)insurance market to cover more risks, therefore contributing to climate change adaptation.
Read full responseResponse to Review of measures on taking up and pursuit of the insurance and reinsurance business (Solvency II)
25 Aug 2020
The Insurance Europe Reinsurance Advisory Board (RAB) strongly supports the Solvency II framework and its underlying risk-based, market consistent approach.
The RAB’s view is that the current Solvency II framework broadly works as intended. However, the Solvency II review needs to strike the right balance between stability and prudence on the one hand and efficiency and growth on the other. Therefore, the review should focus on fine-tuning existing deficiencies rather than a complete overhaul of the framework.
Given the purposes of the review to mitigate the impact of short-term volatility and support the long-term financing of the economy (objective #1) and ensuring an effective application of the proportionality principle (objective #2), the RAB identified some deficiencies as well as some areas that are essential to reinsurers.
Some changes are needed to reach the objectives of effective proportionality and mitigating volatility. Related to the first one, the recognition of non-proportional non-life reinsurance for ceding companies should be improved in the standard formula. Moreover, basis risk should be more appropriately defined so that it does not unduly hinder the use, scope, and efficiency of risk mitigation via reinsurance. Concerning the mitigation of volatility, the group risk margin calculation should recognise the diversification of risks across the reinsurance group to reflect the reinsurance business model.
Furthermore, in order to not jeopardise objectives #1 (mitigating volatility), #2 (effective proportionality) and #3 (enhanced policyholder protection), the following should be considered: consistency in the treatment of future premiums at group level should be adopted since premiums have been included in the technical provisions and SCR, and it should be recognized that standard formula results are meaningless for benchmarking against internal model results in the area of reinsurance. Moreover, a macroprudential capital surcharge for reinsurers would duplicate the aim of existing requirements without a clear benefit for policyholders nor financial stability as reinsurance is a competitive B2B activity. Similar comments apply with respect to a blanket application of recovery and resolution planning to reinsurers.
An additional objective of the review should be to preserve the international competitiveness of the European reinsurance sector. A justified reduction in overall capital requirements for EU reinsurers should be evaluated in light of this objective. In addition, Solvency II should not create market access restrictions for reinsurance.
Read full responseResponse to Amendments to the implementing rules on solvency applicable to insurers
7 Dec 2018
Please find attached the Reinsurance Advisory Board's comments on the EC consultation on draft proposals for the Solvency II Delegated Regulation.
Read full response