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Het Verbond van Verzekeraars treedt namens de aangesloten verzekeraars op als gesprekspartner voor de politiek, media en andere relevante partijen over onderwerpen die verzekeraars raken.

Lobbying Activity

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

5 Sept 2025

EC Draft Delegated Acts under Solvency II Review General Comments. The Dutch Association of Insurers welcomes the opportunity to comment on the Draft Delegated Acts published by the European Commission under the Solvency II review. The current proposal as put forward for consultation is a step in the right direction. However, several elements needs to be adjusted enabling insurers to take on their role in strengthening the European economy and internal market across Europe. The current drafting of the requirements related to the Volatility Adjustment (VA) goes against the objectives of the Saving and Investment Union. We appreciate improvements to the VA mechanism but remain concerned about the treatment of non-functional currency investments in the calculation of the VA and the granularity of the calculations of the risk correction . Both elements could negatively impact investment decisions by insurers across the European Union. The setting the convergence factor within the Extrapolation mechanism should also work in more volatility interest rate environments. The Directive sets the minimum convergence parameter at 11%, but we support raising it to 15% to enhance stability and mitigate volatility. The application of the principle of proportionality is a right and not a request to be granted. Proportionality must remain a core principle of Solvency II, allowing adaptation of requirements to insurers risk profiles. Greater flexibility in implementation timelines is essential, as well as preserving diversity and supporting EU competitiveness. The new legislation should avoid introducing administrative burdens in areas where it is not needed. The recurring requirement to demonstrate compliance to the satisfaction of the supervisory authority in multiple articles would impose disproportionate burdens. We therefore recommend deleting this phrase and restricting supervisory objections to clearly defined criteria.
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Meeting with Larisa Dragomir (Cabinet of Commissioner Maria Luís Albuquerque), Riikka Torppa (Cabinet of Commissioner Maria Luís Albuquerque)

18 Mar 2025 · Exchange on relevant developments