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European
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Remaining parts of the Health Insurance (Amendment) Act 2025 come into force
On 1 April 2026, the remaining sections of the Health Insurance (Amendment) Act 2025 (the 2025 Act) came into force. In summary:
The employers’ liability and public liability insurance mid-year 2025 data released by the CBI
The Central Bank of Ireland (CBI) published a national claims information database (NCID) report on employers’ and public liability insurance in April 2026, based on data collected up to and including H1 2025. The report’s key findings include:
The report also notes that while lower-value claims (below €150,000) have shown a fall in average compensation costs (down 17% on 2020), large injury claims mean that the average total cost of claims has increased by 2% compared to 2024.
EIOPA’s Letter to EI Institutions on the application of the AI Act in relation to the EU insurance sector
On 13 April 2026, the European Insurance and Occupational Pensions Authority (EIOPA) published a letter on the application of the AI Act to the EU insurance sector, noting the need for clarity in its interaction with existing insurance legislation. The letter highlights that sectoral frameworks, including Solvency II, the Insurance Distribution Directive and DORA, already address a number of risks captured by the AI Act, and raises questions around supervisory responsibilities and oversight.
EIOPA also called for the exclusion of commonly used actuarial models, such as generalised linear models, from the scope of high‑risk AI systems when used in pricing and risk assessment. It proposes targeted amendments under the Digital Omnibus on AI to support a proportionate and risk‑based implementation of the AI Act in the insurance sector.
EIOPA publishes annual report on the costs and past performance of retail investment products across the EU
EIOPA published its annual report on the costs and past performance of insurance-based investment products. Covering the period from 1 January 2020 to 31 December 2024, the report draws on a sample of approximately 6,000 products from 175 undertakings, representing a substantial share of the unit-linked and profit participation market in the EEA.
The analysis indicates that, on aggregate, products delivered positive net returns, with investment activity concentrated in low to medium risk profiles. Bancassurance remains the principal distribution channel, while online sales account for a relatively small proportion of premiums. The report also identifies differences in performance and cost levels across products, firms and jurisdictions, with EIOPA highlighting the role of product oversight and clearly defined target markets in assessing value for consumers.
Consultation process open on the treatment of proportional reinsurance treaties
On 15 April 2026, EIOPA launched a consultation on the treatment of proportional reinsurance treaties where certain features may undermine the alignment between the solvency capital requirement (SCR) relief and the effective transfer of risk. The final guidance is intended to be included as an annex to its earlier opinion on risk mitigation techniques. EIOPA noted that certain proportional reinsurance treaties include features such as loss limits or sliding-scale commissions that may significantly reduce the risk transferred, while the impact on the SCR may be limited. In such cases, the SCR relief may not correspond to the level of risk transfer, resulting in a mismatch between SCR relief and risk transfer. The consultation is open until 17 July 2026.
Technical specifications for SNCUs and SNCGs published
Following the review of the Solvency II Directive, EIOPA has published technical specifications for small and non-complex undertakings (SNCUs) and groups (SNCGs). The specifications are intended to support undertakings and supervisory authorities in identifying eligible firms and calculating the relevant risk indicators.
The Solvency II review introduces a proportionality framework aimed at improving the application of prudential requirements for European (re)insurers, considering the nature, scale and complexity of risk. A central element of this framework is the creation of the SNCU and SNCG categories. In introducing the framework, EIOPA intends to provide for a more proportionate application of requirements, including governance and quantitative requirements.
EIOPA and the European Stability Mechanism publish discussion paper on national catastrophe risk management
On 9 April 2026, EIOPA and the European Stability Mechanism (ESM) published a discussion paper on national catastrophe risk management. The paper sets out a proposed European risk-sharing mechanism in response to the level of uninsured natural catastrophe losses in Europe. The proposed mechanism comprises:
EIOPA launch public consultation regarding the shortening of Solvency II guidelines
EIOPA launched a consultation on shortening 13 sets of guidelines under Solvency II on 15 April 2026. The exercise forms part of the Solvency II review and is intended to contribute to simplification of the framework and a reduction in administrative burdens. It covers guidelines across a range of areas, including Pillar I and key Pillar II topics such as the system of governance and the own risk and solvency assessment. EIOPA notes that the consultation is confined to reducing the length of existing guidelines. It does not introduce new requirements or substantive amendments and will close on 8 July 2026.
EIOPA and JRC sign memorandum of understanding to further research natural catastrophe risks
EIOPA and the European Commission’s Joint Research Centre (JRC) have entered into a memorandum of understanding (MoU) on cooperation in the area of natural catastrophe risk, with a view to improving the assessment of such risks and their impact on the insurance sector and the wider economy. The MoU provides for cooperation aimed at improving the understanding and assessment of natural catastrophe risks, including:
EIOPA publishes a study on market and credit risk conducted in respect of 2024
EIOPA published the results of its year-end 2024 comparative study on market and credit risk modelling under Solvency II. The study forms part of ongoing supervisory monitoring of internal models and compares outputs across undertakings. It identifies variation in model results for certain asset classes, reflecting differences in calibration approaches and underlying assumptions. It also highlights differences across firms in the treatment of specific asset exposures and in sensitivities to market risk factors. EIOPA highlights that the study’s findings point to internal model outputs remaining an important area of supervisory focus.
Revised guidelines published on the systematic exchange of information within colleges of supervisors
EIOPA published revised guidelines on the systematic exchange of information within colleges of supervisors. The updates relate to cooperation between national competent authorities responsible for the supervision of cross‑border insurance groups in the European Economic Area (EEA). The revisions include:
EIOPA to undertake second coordinated mystery shopping exercise across several EU Member States
EIOPA announced that it will undertake a second coordinated mystery shopping exercise across a number of EU Member States. The exercise will focus on the online distribution of non-life insurance products, following an earlier EU‑wide exercise on insurance-based investment products conducted in 2024.
It will involve national competent authorities assessing the consumer purchasing journey, including the provision of information and sales practices. The exercise will be conducted across ten Member States, with results expected in the second half of 2027.
EIOPA’s insurance risk dashboard shows overall stability, with geopolitical uncertainty shaping the future outlook
EIOPA published its April 2026 insurance risk dashboard, relying on Solvency II data and risk indicators from Q4 2025 and year-end 2024. The dashboard aims to illustrate the principal risks in the EU insurance sector through data gathered from insurance groups and undertakings within the EU. The dashboard covers a wide range of risks from credit to ESG-related risks.
The dashboard shows that risks in the sector remain stable at a medium level. Macroeconomic risks continue to be influenced by elevated inflation expectations and ongoing geopolitical tensions. Insurance risks are at a medium level, supported by strong premium growth and stable underwriting performance, however uncertainty in respect of marine, aviation and trade-related claims continues.
EIOPA submits draft technical standards on the functioning of resolution colleges and on reporting requirements for resolution plans under IRRD
On 24 April 2026, EIOPA submitted two draft technical standards to the European Commission to support the implementation of the EU’s Insurance Recovery and Resolution Directive (IRRD), which is due to take effect in 2027.
The Regulatory Technical Standards (RTS) set out how resolution colleges should operate. The RTS contain provisions on how colleges should collaborate when developing resolution plans, assessing resolvability and addressing impediments to resolvability.
The Implementing Technical Standards (ITS) set out standard procedures, forms and templates for insurers to use when providing information required for resolution planning. The ITS are designed to ensure resolution authorities receive the information they need, while keeping demands on insurers proportionate by focusing only on essential information that cannot be sourced elsewhere.
Date published: 30 April 2026
This publication provides an overview of certain legal and regulatory developments that may be of interest to certain entities. It does not purport to provide analysis of law or legal advice and is strictly for information purposes only.