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Department of Finance publishes action plan for insurance reform
The Department of Finance, in conjunction with the Departments of Justice and Enterprise, has published an action plan for insurance reform from 2025 to 2029. The action plan is focused on a number of key themes, in particular:
There are 26 actions outlined in the action plan with ten having been identified as priority actions. Among these are:
EIOPA publishes its oversight activity report for 2024
The European Insurance and Occupational Pensions Authority (EIOPA) has published its oversight report for 2024. This report, which details EIOPA’s oversight activities over the past year, illustrates EIOPA’s efforts to strengthen supervisory capacity and promote supervisory convergence across the EU. The report notes EIOPA’s efforts in addressing prudential and conduct-related issues, particularly regarding cross-border business. The report also shows EIOPA has conducted a range of activities to identify, monitor and address conduct risks in various areas including:
The report highlights EIOPA’s aim to enhance supervision and the application of key regulatory frameworks, including Directive 2009/138/EC on the taking-up and pursuit of the business of Insurance and Reinsurance (Solvency II) and Directive (EU) 2016/97 on insurance distribution.
EIOPA consults on proposed amendments to supervisory reporting and disclosure requirements to ease burden on insurers
EIOPA has published a consultation package on amendments to public disclosure and supervisory reporting requirements under Solvency II. The aim of these amendments is to ease the reporting burden on (re)insurers. Further to amendments to the implementing technical standards (ITS) on supervisory reporting and on public disclosure, are draft revised guidelines on reporting for financial stability purposes and draft revised guidelines on the supervision of branches of third country insurance undertakings.
The revision of the ITS was triggered by the need to incorporate changes introduced during the review of Solvency II in the templates for supervisory reporting and public disclosure. By reducing the frequency of certain templates, deleting some annual templates, making greater use of proportionality principles and introducing technical simplifications across the framework, this allows the level of reporting to be reduced overall. The consultation package also addresses inconsistencies highlighted since the last revision of the ITS in 2023. EIOPA has expressed confidence that the package would lead to a significant burden reduction for European (re)insurers.
EIOPA submits first bundle of technical standards to the European Commission after the review of Solvency II
On 14 July 2025, EIOPA made submissions to the European Commission in support of the implementation of the reviewed Solvency II Directive. EIOPA’s submissions included three technical standards and one set of revised guidelines, covering undertakings under dominant / significant influence or managed on a unified basis; relevance of cross-border activities of undertakings; regional governments and local authorities’ exposures; and undertaking-specific parameters.
The European Commission has three months to decide whether it will adopt the draft technical standards. Once adopted, the standards will be a guide to new features under the reviewed Solvency II, new features, and will support supervisory cooperation and effectiveness.
EIOPA sets out guidance for supervising mass-lapse reinsurance and reinsurance termination clauses
On 15 July 2025, EIOPA published two annexes to its opinion on the use of risk-mitigation techniques by insurance undertakings from 2021. The first annex gives further guidance to supervisors on the treatment of mass-lapse reinsurance, promoting greater supervisory convergence across Europe in the context of evolving risk mitigation methods through the use of reinsurance. The second annex deals with specific terms of reinsurance agreements' termination clauses that could compromise the effective transfer of risk.
Commission seeks feedback on the review of the Solvency II Delegated Regulation
The European Commission has published a draft delegated act reviewing the Solvency II Delegated Regulation. The Commission is seeking feedback regarding changes to a number of technical rules governing:
These changes seek to remove barriers for insurers to facilitate the long-term financing of the European economy. The draft delegated act proposes a dedicated treatment for long-term equity investments by insurers that aims to encourage equity financing of European firms. It suggests measures to reduce the impact of short-term market volatility on solvency positions. The draft also proposes a recalibration of capital requirements for natural catastrophe risks to echo modern scientific insights regarding climate change. The Commission invites all stakeholders to submit their views by 5 September 2025.
EIOPA monitoring exercise marks progress in the integration of climate change considerations into insurers’ risk assessments
EIOPA issued a public statement on 23 July 2025 addressing the findings from a monitoring exercise that it carried out to explore how (re)insurers are addressing climate change-related risks in their own risk and solvency assessment (ORSA). The results indicate that (re)insurers have made significant progress in integrating climate change-related risks into their risk management frameworks. Most insurers surveyed were found to include climate change risk assessments in their ORSAs, covering both transition and physical risks. The exercise has also highlighted important challenges.
Among the challenges identified are significant variations in approach to assessment of climate change risk across jurisdictions, limited availability of high-quality data, and the difficulty of extending the time horizon of analyses beyond what is to be expected for ORSA.
EIOPA publishes monthly technical information for Solvency II
EIOPA published its monthly technical information on 3 July 2025 regarding the relevant risk-free interest rate term structures, with reference to the end of June 2025, for Solvency II purposes. This technical information is used for the calculation of technical provisions for (re)insurance obligations. On the same date, as is usual, EIOPA also published technical information on the symmetric adjustment of the equity capital charge under Solvency II with reference to the end of June 2025.
On 4 July 2025, EIOPA also published the biannual shifted risk-free rate term structures. These term structures are applied to calculate the option-adjusted duration of technical provisions which must be reported according to the guidelines on reporting for financial stability purposes.
EIOPA launches consultation on revised guidelines on exchange of information within colleges
On 14 July 2025, EIOPA launched a consultation on its proposal for revised guidelines concerning the exchange of information on a systematic basis within colleges of supervisors. The guidelines expand on the existing framework introduced in 2015 and seek to encourage greater cooperation and consistency of information sharing across National Competent Authorities (NCAs) responsible for the supervision of cross-border insurance groups within the European Economic Area (EEA).
Features of the new guidelines include provisions relating to the sharing of group ORSA reports, streamlining in technical annexes and updating legal references to ensure regulatory alignment. The consultation runs until 14 October 2025.
EIOPA opens consultation on rules for resolution colleges and reporting requirements under IRRD
EIOPA launched two consultations on 22 July 2025 relating to the implementation of the EU’s Insurance Recovery and Resolution Directive (IRRD). The first paper consults on draft regulatory technical standards for establishing and operating resolution colleges for insurance groups, addressing matters such as, collaboration among supervisory colleges in developing resolution plans, group resolvability assessments and measures to addressing impediments to resolvability.
Meanwhile, the second consultation paper sets out templates and procedures for insurers to report resolution planning data. Both consultations run until 31 October 2025.
EIOPA highlights progress in follow-up to peer review on outsourcing
On 24 July 2025, EIOPA published a follow-up report to its 2022 peer review on outsourcing under the Solvency II framework. The report assesses how NCAs have implemented recommendations issued by EIOPA with the aim of enhancing consistency and effectiveness in outsourcing supervision by NCAs across the EEA. Overall, of the 77 actions recommended by EIOPA to NCAs, 51 were fully implemented, 22 partially fulfilled and four remain unfulfilled. EIOPA noted several positive developments in outsourcing supervision, including refined regulatory tools, detailed guidance and improved internal procedures on outsourcing.
Areas identified by EIOPA as requiring further attention include off-site supervision, tool operationalisation and the consistent embedding of internal procedures still require attention.
EIOPA publishes Insurance Risk Dashboard
EIOPA has published its July 2025 Insurance Risk Dashboard based on Solvency II data for Q1 2025 Solvency II data and Q2 2025 market data. 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 are currently stable in the EU's insurance sector. However, there are persistent vulnerabilities stemming from high market volatility, trade uncertainty and an uncertain geopolitical environment. At a macro risk level, global GDP forecast has revised down while long-term interest rate declines and fiscal pressures continue, however geopolitical conflicts weight on sentiment.
For more information on these topics please contact any member of A&L Goodbody's Insurance & Reinsurance team.
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.