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UNIÓN ESPAÑOLA DE ENTIDADES ASEGURADORAS Y REASEGURADORAS

UNESPA

La misión de UNESPA es representar a sus asociados ante todo tipo de instituciones y organismos, tanto nacionales como internacionales, y transmitirles el punto de vista del seguro.

Lobbying Activity

Meeting with Karola Maxianova (Head of Unit Secretariat-General), Raquel Cortes Herrera (Head of Unit Secretariat-General)

11 Nov 2025 · Exchange of views on the upcoming pension package

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

6 Nov 2025 · Supplementary pensions

Meeting with Jonás Fernández (Member of the European Parliament)

22 Sept 2025 · Saving and Investment Union

Response to Delegated Regulation supplementing the review of prudential rules for the insurance and reinsurance sector (Solvency II)

5 Sept 2025

UNESPA (Spanish Association of Insurers and Reinsurers) appreciates the opportunity to comment on the European Commission review of Solvency II technical rules. UNESPA is the representative body of 186 private insurers and reinsurers that stand for approximately 98% of the Spanish insurance market. As member of Insurance Europe, UNESPA has been involved in all relevant documents and discussions led by the European federation in the context of this consultation. Accordingly, UNESPA fully supports the position expressed by Insurance Europe in its response. Nevertheless, UNESPA would like to take this opportunity to emphasize several points, which are also included in Insurance Europes response and are attached in the annex to this submission.
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Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

21 Jul 2025

UNESPA welcomes the European Commissions initiative to strengthen supplementary pensions as part of the broader ambition to build a European SIU. Enhancing retirement income adequacy, fostering long-term investment, and increasing pension participation are crucial objectives, especially in light of demographic shifts and the evolving landscape of national pension systems. The Draghi report notes that in 2022, the level of pension assets in the EU was only 32% of GDP (8% in the case of Spain in 2024). For this reason, it is essential to develop a common framework for long-term savings and supplementary pensions in Europe to help achieving the objectives of the SIU and generate significant savings in Europe. Views on key areas of the EC call for evidence: - Automatic enrolment: It is important to develop a common framework that allows the implementation of automatic enrolment throughout the EU, in particular in those countries in which the second pillar is very underdeveloped (as is the case in Spain, where only 12% of workers have an occupational pension plan). Auto-enrolment can increase the participation rates of all kind of workers (particularly, young people, women and low-medium income workers) and enhance returns to pension-holders by delivering the benefits of greater scale and capacity to diversify. Therefore, automatic enrolment should be promoted more widely across the EU. - Pension tracking systems are valuable tools to enhance transparency, increase awareness, and empower individuals to plan their retirement. In particular, they increase awareness of citizens about their expected retirement income and so support better financial planning. Providing all European citizens with clear information (both online and in paper format) about future public and private pension entitlements, in order to raise awareness of the need for savings, would help many of them make informed decisions about their pensions. For this reason, it is considered important that the European Commission recommends implementing these systems, especially in those countries that do not yet have them or where they do not work well. Experience in other European countries that have already implemented this measure shows that it is the most effective way to make citizens aware of the pension gap, encouraging them to start saving systematically from a young age. - Pension dashboards at a European level could be an essential tool to support the European Commission and national policymakers in monitoring the adequacy and sustainability of pension systems and in closing pension gaps. This dashboard should consider the impact of measures adopted by Member States to promote supplementary pension schemes as an important factor in reducing the pension gap. - Pan-European Personal Pension Product (PEPP): Despite its ambitious objectives, the PEPP has failed to gain traction across the EU, with only one provider registering a PEPP to date. As EIOPA has noted, this limited uptake stems from structural, rather than circumstantial, issues. Several factors have contributed to the PEPPs limited appeal. Among them are the obligation to offer national compartments in at least 2 Member states, the requirement for products to outperform inflation and a strict 1% annual fee cap for the basic PEPP. Given these challenges, any review of the PEPP would need to focus on addressing all the issues that have resulted in this situation. - Tax incentives: For the development of supplementary pensions, attractive tax incentives are key. The latest reform as regards complementary pensions carried out by the Spanish Government aimed to foster occupational pension schemes, but this was done to the detriment of individual pension schemes. The reduction in the contribution limits to individual pension schemes in 2021 and 2022 has resulted in a decrease in retirement savings, without any substantial increase in savings in occupational pension schemes.
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Response to Recommendation on savings and investment accounts

7 Jul 2025

UNESPA (Spanish Association of Insurers) welcomes the EC´s objective to channel more retail savings into productive investments aligned with the EUs priorities, and the opportunity to provide comments to the Call for Evidence (CfE). The insurance industry is one of Europes largest institutional investors and an important provider of stable, long-term funding. Insurance savings products have proved to be an effective conduit for channelling retail savings into investment. To date, close to 9.5 trillion has been invested in the economy, with 70% of insurers' investments in European assets (in Spain, 88%). Views on key areas of the EC call for evidence: 1. Providers of the savings and investment accounts In its Communication of 19 March 2025, the European Commission announced measures to create a European blueprint for savings and investments accounts or products based on existing best practices accompanied by a recommendation addressed to the Member States on the tax treatment. But the CfE only refers to savings and investment accounts without mentioning the term 'products'. Regarding this issue, the term 'account' can give rise to confusion (it can be understood as a banking account only). European insurers can play a key role in achieving the SIU goals and including insurers as providers of these accounts in the Recommendation is essential to reach a wider audience and ensure a wider uptake. We propose to substitute the term account by a more neutral one, that reflects the variety of possible providers. For example, the more generic term wrapper is used in the Finance Europe label (this term is used hereinafter instead of the term account). This label is open to a wide range of providers, including insurance undertakings. Another possibility would be solution or product. In case that the term "account is maintained, it should be clarified that it can be supplied by different financial undertakings, including insurance undertakings. 2. Eligibility of products that could be accessed via a savings and investments wrapper As long as there are sufficient tax incentives to justify subjecting investments to certain requirements, the approach adopted by the "Finance Europe" label is considered reasonable. We agree with the criterion of setting a minimum investment threshold in European assets within the wrapper. The investment universe of the underlying assets that could be accessed via the wrapper should be as wide as possible. With regard to the scope of eligible assets, it should include both liquid (e.g. equity, corporate bonds, UCITS, governments bonds for diversification purposes) and less liquid (e.g. securitisations, infrastructure assets and alternative assets such as ELTIFs, private equity/debt and venture capital) underlying assets. Insurance undertakings should be providers of the wrapper (rather than insurance products to be included as underlying investment options within the wrapper). 3. Tax treatment For the success of the SIU, attractive tax incentives are key. There is no silver-bullet solution. The Swedish ISK (and its equivalent insurance product, Endowment Insurance) can be a positive example but it may be not appropriate to try to export this exact product to other countries. In other markets, other long-term savings and investment products, with different characteristics can equally be suitable ways to achieve the SIU goals. Additionally, the tax treatment of the ISK can be simple, but it does not always mean a tax incentive. Wrappers should be designed to incentivize through attractive tax incentives a long-term holding period in order to provide stable, long-term funding. it is essential to ensure that this initiative does not worsen existing tax regimes applicable to eligible wrappers. It must be ensured that this initiative leads, in all cases, to an improvement of the current fiscal frameworks applicable to savings and investment products across Member States.
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Meeting with Maria Luís Albuquerque (Commissioner) and

26 May 2025 · SIU and Pension System

Response to 2025 Strategic Foresight Report

19 Mar 2025

The insurance industry works every day to protect people and businesses. UNESPA is the Spanish Association of Insurers and is member of Insurance Europe. The association was founded in 1977 and represents approximately 200 insurers that together cover almost all the insurance business in Spain. These undertakings have a turnover of 62,000 million euros every year, or in other words, almost 5.1% of Spanish gross domestic product (GDP). They protect assets and people, which are valued at more than 10 times the GDP of Spain. UNESPA highly appreciates the focus of the 2025 Strategic Foresight Report on resilience. The Commission efforts to strengthen consistency and synergies between all EU policies aiming to promote long-term resilience will certainly contribute to the success in moving towards a safer and more prosperous future for all Europeans. The insurance industry is willing to work closely and constructively with the Commission, supporting initiatives that strengthen the resilience of Europe's economy and society. That includes initiatives to enhance preparedness and close existing protection gaps in a number of areas, such as climate risks or cyber risks, among other threats and hazards, as highlighted in the Niinisto report. To enhance preparedness, policymakers should carry out initiatives to raise awareness among citizens and businesses about risks facing them and their properties and about existing protection gaps. Policymakers should also implement initiatives to increase the insurability of risks. That would include risk prevention and risk protection awareness policies for both the public and private sectors. Furthermore, appropriate regulatory frameworks for prevention should be developed and appropriate incentives should be established for companies to invest in these prevention and protection measures, including financial support to SMEs by public aid through European funds. Insurance coverage provides financial protection and helps swift recovery from damage, but insurers cannot provide cover without data. Therefore, policymakers should ensure insurers can access and make use of data. This includes allowing customers to consent to sharing data from their vehicles, apps, and personal devices. Data is vital across all areas of insurance for pricing, risk analysis, risk mitigation and prevention, innovation, and fraud detection and prevention. In order to close the protection gap in the EU, public-private partnerships should be promoted, in particular in the area of increasingly frequent and severe extraordinary climate risks. The EU faces significant investment requirements to address climate change, enhance security, attain self-sufficiency in energy, food, and technology, and finance growth. To meet these demands, it is essential to close the pension savings gap and to increase retail investments including through insurance savings and retirement products. Closing the pension savings gap and providing financial security for individuals in a context of ageing populations, requires the implementation of measures such as: pension savings gap calculation tools to inform all workers annually about their estimated future pension; incentives to savings in supplementary occupational (second pillar) and individual (third pillar) pension schemes, the development of automatic enrolment employment systems; or the development of a pension dashboard, as proposed by the European Insurance and Occupational Pensions Authority (EIOPA) to monitor the evolution of the three pillars of pension systems in the Member States. To increase the retail participation in the financial markets, policymakers should simplify and modernise the investment process for Europeans, providing clear and streamlined customer information and avoiding disproportionate burden for financial providers without significant added value for customers. Finally, policymakers should continue efforts to strengthen the dialogue with all key stakeholders.
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Response to Savings and Investments Union

6 Mar 2025

UNESPA welcomes the European Commissions plan to create a new Savings and Investments Union (SIU) and will continue to develop proposals and engage in discussions on future solutions to make the SIU a success. It is essential to develop a common framework for long-term savings and supplementary pensions in Europe to help achieving the objectives of the SIU and generate significant savings in Europe. The experience with the Pan-European Pension Product (PEPP) has shown that EU products are not easy to make work in practice. Given the variety of products offered in the market, there is no need to introduce a new pan-European saving and investment product. The promotion of SIU should be based on existing products which are already well-known by retail investors and have the potential to quickly attract a substantial amount of savings. These products should be supported at the EU level, provided they have some specific characteristics common to all Member States, some of which are set out in the Noyer Report, among which the following are proposed: A long-term investment horizon. Restricting the liquidity of savings is a necessary step to meet long-term investment needs. Liquidity should be restricted to extraordinary needs. Attractive, stable and homogeneous tax treatment throughout the EU, both for occupational and individual pension schemes. Regarding occupational pension instruments, it is important to develop a common framework that allows the implementation of automatic enrolment throughout the EU. Research indicates that employees are more inclined to join pension schemes through auto-enrolment as long as they have the option to opt out. The labelled products should not be backed by a full capital guarantee. A non-time-bound capital guarantee restricts the ability of institutional investors to invest in long-term assets. It would be possible to provide a capital guarantee or financial protection at maturity alone (i.e. at retirement), but not in the event of early withdrawal. The decumulation of private pension schemes in the form of long term/lifetime annuities should be encouraged by means of tax incentives to truly supplement public pensions. Transforming a property into a long term/lifetime annuity (monetization of real estate assets) should also be encouraged by means of tax incentives. Ensure that the Retail Investment Strategy (RIS) contributes to the SIU objectives to allow easy access to investment products for retail investors. Ensuring that the long-term retirement savings of European citizens contribute to the transformation of the European Union requires the creation of suitable and attractive assets. The following actions are proposed: To increase scale and access to venture capital, SME debt and equity, assess successful national funds and how their use can be expanded to other EU markets or potentially multi-national/EU versions, involving financial instruments such as Invest EU. Evaluate public-private financing mechanisms (blended finance). Partial guarantees can reduce barriers to greater investment and should be recognised under Solvency II Revise the securitisation framework to facilitate the use of this instrument. Facilitate cross-border investment by reducing the fragmentation in insolvency laws. Align the prudential framework (Solvency II) with the strategic objectives of the Savings and Investment Union. Allow the recycling of gains or losses on realisation for equity instruments measured at Fair Value through Other Comprehensive Income (FVOCI) under IFRS in order to promote long-term equity investments in Europe. In addition, it is essential that measures are taken to raise awareness among European citizens, especially the youngest, of the need to save for the long term through insurance products and supplementary pension schemes (public and private campaigns to promote savings, pension tracking systems, pension dashboard, etc.).
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Meeting with Pablo Arias Echeverría (Member of the European Parliament)

10 Dec 2024 · Priorities of the Spanish insurance sector to continue advancing in the European project in general, and upcoming parliamentary work by IMCO that will impact the sector.

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness), Nathalie De Basaldua (Cabinet of Commissioner Mairead Mcguinness) and LLORENTE Y CUENCA, S.L

25 Sept 2024 · Contrib. of insurance sector to societal goals of sustainability & digital transformation, compl. pensions, Code of conduct on right to be forgotten, new pol. cycle (Draghi/Letta)reports), reduction of adm. burden securitization, DORA & FIDA

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis)

24 Sept 2024 · Upcoming mandate, Implementation and simplification

Response to Prolongation of the US provisional equivalence decision Art 227 Solvency II

4 Mar 2024

UNESPA is the Spanish Association of Insurers. The association was founded in 1977 and represents approximately 200 insurers that together cover almost all the insurance business in Spain. These undertakings have a turnover of 62,000 million euros every year, or in other words, almost 5.1% of Spanish gross domestic product (GDP). UNESPA, as member of Insurance Europe, has contributed to the development of the European insurance industry response to the EC consultation on the prolongation of the U.S. provisional decision under Solvency II. Comments and suggestions below should be considered together with those of the European insurance industry federation. UNESPA supports the renewal of provisional equivalence within the Solvency II regime for the United States., according to Article 227 of the Directive. The reasons and criteria that supported the first provisional equivalence designation of the U.S. regime are still valid and nothing should prevent the renewal. While deciding on the prolongation of the provisional equivalence and without implying any delay on that decision, the Commission is asked to clarify that the provisional equivalence of the U.S. applies to Puerto Rico, considering both its status as U.S. territory and the fact that Puerto Rico Office of the Commissioner of Insurance is member of the National Association of Insurance Commissioners (NAIC) following exactly the same solvency regime as the rest of the U.S. UNESPA considers that the same reasoning supported for the U.S. should also apply to the renewal of equivalence decisions for other countries such as Brazil, Mexico, Canada and Japan. Once the prolongation of the existing provisional equivalence decisions is confirmed, and as a separate step, UNESPA encourages the Commission to consider the extension of provisional equivalence to other jurisdictions, including Chile, Peru, and Colombia, when they meet the criteria applied to the other third countries already covered. In case of unexpected delays in determining the provisional equivalence of any of the abovementioned third country regimes, Commission should not stop or delay the assessment regarding the rest of jurisdictions.
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Response to Retail Investment Package

28 Jul 2023

UNESPA is the Spanish Association of Insurers. It was founded in 1977 and represents approximately 200 insurers that together cover almost all the insurance business in Spain. These undertakings have a turnover of 62,000 million euros every year, or in other words, almost 5.1% of Spanish GDP. UNESPA supports the objective of the Retail Investment Strategy (RIS) presented by the European Commission to enhance citizens trust and confidence and increase retail investors participation in capital markets. To reach that objective a robust legislative framework is needed, where consumers are enabled to invest easily through different types of products, including insurance-based investment products (IBIPs). The proposal includes relevant amendments which are deemed to have a positive impact on the market such as: the digital by default approach, promoting financial education and prior consumer testing on disclosures. However, some of the proposals in the package raise serious concerns for the insurance industry, either because they dont consider properly the specific nature of IBIPs or because they put additional burden and complexity on the distribution of investment products. The main concerns of the Spanish insurance industry as well as concrete suggestions to amend the Commission´s proposal are presented in the annex and summarised below. Best interest of costumers: The new specific criteria to define the best interest seem difficult (in certain cases impossible) to implement in practice by insurance manufacturers and distributors and may ultimately have a negative impact on costumers. Inducements in non-advised sales: The remuneration of the work by the distributor under this model (including collection of information and appropriateness test) is not only legitimate, but also constitutes a necessary incentive to stimulate the demand for investment products by consumers and increase their participation in the capital markets, allowing them to make informed investment decisions. Value for money of IBIPs: The publication of benchmarks would function as a price control mechanism, outside the mandate of EIOPA and national competent authorities under IDD. This would be inconsistent with the principles of a market economy and freedom of competition. Benchmarks are also subject to important limitations, taking into account the heterogeneity of IBIPs products and the impossibility of capturing in an index qualitative elements of great importance for the client. Suitability and appropriateness tests: With the new requirements, the IBIP distribution process is not only not simplified (as would be desirable to achieve the objectives of RIS), but also becomes more complex, increasing burden on distributors and making it even more difficult for consumers to access these products. Disclosures: Transparency requirements should become simpler, to avoid overloading consumers with too much information. Instead of delivering additional documents, it would be preferable to provide information through documents already used by undertakings. Marketing: new requirements should not impose disproportionate burden on insurance undertakings and insurance intermediaries, for example through specific periodic reports to the management board or disproportionate record keeping requirements. Timelines: The timeline is unrealistic, making impossible for both authorities and market participant to properly implement the new rules and requirements on time, given the significant compliance and operational effort required. In addition, the proposed review clause of 3 years is too short, as well as too focused on a single element of the proposals, losing sight of the overall goal of RIS. Scope of PRIIPs: The exemption of immediate annuities should be clarified with simpler and clearer wording. Exclusion should be extended to certain retail insurance products that rely on relevant biometric coverages difering from pure investment products.
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Meeting with Adrián Vázquez Lázara (Member of the European Parliament, Committee chair)

27 Apr 2022 · General exchange of views

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

25 Aug 2020

UNESPA (Spanish Association of Insurers and Reinsurers) appreciates the opportunity to comment on the European Commission Inception Impact Assessment on the 2020 Review of Solvency II. UNESPA is the representative body of 195 private insurers and reinsurers that stand for approximately the 96% of the Spanish insurance market. Spanish insurance undertakings generate a premium income of more than € 65 bn, directly employ 48.000 people and invest more than € 324 bn in the economy. UNESPA, as member of Insurance Europe has taken part in all Insurance Europe documents linked with this project and firmly supports the Insurance Europe position on this matter. Our comments should be considered together with the European industry position. However, in addition to the Insurance Europe position, we would like to highlight some issues regarding the following subjects included in the attached file: - Long-term guarantee measures. - Proportionality. - Threshold for exclusion from Solvency II (article 4 from the Directive 2009/138/EC). - Climate and environmental risks. - Cross-border activities and IGSs.
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Meeting with Andrea Beltramello (Cabinet of Vice-President Valdis Dombrovskis)

28 Nov 2018 · Solvency II

Response to REFIT review of the Motor Insurance Directive

12 Jul 2018

UNESPA coincide en casi todos los aspectos tratados en la propuesta: control del aseguramiento, la actualización de los límites del Seguro Obligatorio del Automóvil (SOA) y la cobertura de las insolvencias de las aseguradoras por los Fondos de Garantía. No obstante, por lo que se refiere a la delimitación del ámbito de la Directiva, se propone el siguiente texto: ”1 bis) “circulación de un vehículo”: toda utilización de ese vehículo, principalmente destinado a servir de medio de transporte en el momento del accidente, que sea conforme con la función habitual del vehículo, independientemente del terreno en el que se utilice el vehículo automóvil y de si está parado o en movimiento;. Quedan excluidos de esta definición, la utilización de un vehículo como instrumento en la comisión de actos dolosos así como su uso en pruebas deportivas.” En relación con el ámbito de la Directiva y la propuesta de modificación del art. 1 con la incorporación del concepto de “uso del vehículo”, UNESPA propone: • Respecto al uso del vehículo destinado normalmente a servir como medio de transporte, se considera que resulta de capital importancia utilizar los mismos términos de la sentencia del caso C-514/16 Rodrigues Andrade y, posteriormente, de la sentencia del caso C-334/16 Nuñez Torreiro, en el sentido de que la utilización del vehículo para que esté cubierto por el SOA dependerá de que la función principal del mismo sea como medio de transporte en el momento del accidente pero no en otros supuestos, en los que pudiera ser utilizado como una maquinaria de trabajo (vehículos mixtos, industriales o agrícolas) en ese preciso instante. • Sobre la mención que se hace en la definición “independientemente de las características del vehículo”, se trata de un nuevo concepto que se ha introducido y que no proviene de la Jurisprudencia del TJUE, por lo que habría que eliminarlo para no ampliar el ámbito de la Directiva en exceso, ya que de lo contrario, quedarían bajo la necesidad de aseguramiento todo tipo de vehículos (bicicletas, sean eléctricas o no, patinetes, segways…). Por ello, se propone: o Eliminar este término manteniendo la definición de “vehículo” que se hace en art. 1.1 de la Directiva y que se refiere a vehículo automóvil, lo que hace pensar en el no aseguramiento de ese tipo de vehículos. o De no ser posible, incorporar en la definición la mención a que sean vehículos automóviles que puedan circular de forma autónoma y que no necesiten de una fuerza de propulsión externa, como las bicicletas o patinetes, así como las bicicletas eléctricas, que combinan propulsión interna y externa. o De no aceptarse lo anterior, quedando abierto el ámbito de la Directiva a todo tipo de vehículos, se debería poner de manifiesto la necesidad de ayuda de las autoridades de Tráfico para poder identificar y llevar a cabo el control de aseguramiento de dichos vehículos. • Por otra parte, es necesario excluir expresamente de la definición ciertos supuestos, como la utilización del vehículo como un instrumento para la comisión de actos dolosos, así como su uso en pruebas deportivas. Asimismo, en referencia a los certificados de siniestralidad, se propone: • Como primera opción, eliminar el formato estandarizado, así como la necesidad de tener en cuenta estos certificados por las aseguradoras en el cálculo de la prima, debiendo publicar la política de la entidad en cuanto al tratamiento del bonus-malus. Todo ello, sobre la base de la libertad de mercado para que los operadores puedan tener en cuenta las variables que consideren oportunas en el cálculo de las primas, pudiendo ser o no la siniestralidad una de ellas. • De no aceptarse lo anterior, se propone eliminar la mención al importe de los siniestros, de forma que la tarificación se pueda basar en el número de sinestros y no en su coste económico, como se hace en numerosos mercados.
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Response to REFIT review of the Motor Insurance Directive

28 Jul 2017

MORE FEEDBACK IN ATTACHS Claims history: We cannot consider as suitable any of the proposals. Our industry does not discriminate new policyholders because of coming from different MS. Those are treated as domestic ones. Claims history is only one more of the concepts considered when calculating the MTPL premium. Each insurance company must be free to set those parameters, in benefit of consumers. Nevertheless, there could be another option. Insurance Europe worked in the recent past in non-binding guidelines regarding this issue. Our market took over these, including a commitment in its Guide of better motor insurance practices, to provide the claims history including a minimum of information, and in English if required. The MSs could act in a similar way. Protection of victims:There is no the case for an EU guarantee fund. The actual framework it is right. But it would be necessary to solve certain gaps and clarify how GFx should work. Insolvency should be included under the MID as a case covered by the motor insurance GFs. The GF of the MS where the vehicle is normally based should intervene the first, as if the claim was for an accident caused by an uninsured or untraced vehicle. The victims would have recourse to their own GF. Then, the GF of the MS of the insolvent insurer should reimburse the outlays of the host MS. Minimum amounts: Our legislation sets limits higher than the minimum amounts (70MM per loss for personal injuries and 15MM for property). The current procedure and periodicity should be changed such that there are no longer differences between the MSs with the transition period and those without it. Scope:Vnuk case will have implications in Spanish regulation, as the concept of use of vehicle would be opposed to our legislation. Despite our law does not make difference between public and private areas, it does make it over certain activities of some vehicles. We support the modification of the MID in order to clarify the used in traffic concept (option 3). The "used in traffic" definition of MID could improve the current situation. It seems to limit the fact covered by the MTPL to use is given to the vehicle in the traffic area. However, the new term introduced "in areas where the public has access”raises the doubt to what places is referring to. It would be desirable to provide greater legal certainty to the terms introduced. For this, we propose to define what is fact circulation, but incorporating certain qualifications and exclusions. The definition would come from two ways: (1) As for the reference “in areas where the public has access”, adding that in these areas should govern traffic and road safety rules, to exclude areas governed by different laws (ie ports&airports). However, it also would cover the MTPL events in any way or land, public or private, urban or interurban, (2) As for the type of activity, to exclude activities such as industrial, agricultural or motor sports to be covered by other insurance different to MTPL). Economic impacts:Due to Vnuk, all the insured vehicles would be directly impacted. In Spain, tractors, industrial vehicles and motor sport vehicles are not covered by MTPL while developing agricultural or industrial activities, or competing. MTPL only will cover them when circulating and not doing those activities. Our ruling excludes as well vehicles circulating in special areas like ports and airports. Nevertheless, these activities are covered by liability insurance. Tractors and industrial vehicles insured by liability policies represent premiums for more than EUR 300MM, that will move to MTPL insurance. Our legal system is highly protectionist with victims. For this reason, very high limits were established (limits previously detailed). Currently, 1MM of tractors and industrial vehicles could be covered while doing their activities by liability policies, with an average limit of EUR 300,000. The impact of applying the MTPL system to these activities would be very high.
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Meeting with Mette Toftdal Grolleman (Cabinet of Commissioner Jonathan Hill)

1 Oct 2015 · Introductory Meeting

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen)

28 Jan 2015 · Investment Initiative