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CBI publishes Investment Firm and Intermediary Newsletter
The Central Bank of Ireland (CBI) published its twice-yearly Investment Firm and Intermediary Newsletter, which highlighted a number of recent updates to areas of interest in the insurance space. Key updates covered include:
CBI’s Insurance Newsletter - June 2025
The CBI published its second Insurance Newsletter of the year, highlighting a number of developments for the insurance sector. Of note, the CBI and the European Insurance and Occupational Pensions Authority (EIOPA) are welcoming feedback on a number of consultations including the CBI’s paper on amendments to the Fitness & Probity Regime and EIOPA’s implementation of the Insurance Recovery and Resolution Directive, with consultations closing on 10 July and 31 July respectively.
The CBI has also published its note on planning for the transition to net zero. The note not only aims to guide firms through their own transition but also sets out principles to help firms to assess the transition planning of stakeholders.
EIOPA publishes its Annual Report for 2024
In June, EIOPA published its Annual Report for 2024 (the report). The report reflects on the work done by EIOPA over the previous year, with particular regard to its strategic priorities.
Among those priorities, EIOPA reports success in contributing to building sustainable insurance, through its promotion of sustainable finance by addressing protection gaps, combating greenwashing, and launching a Catastrophe Data Hub for natural catastrophe risk. The report further details EIOPA’s support of the industry in the age of digitalisation, through the implementation of the Digital Operational Resilience Act, promotion of data-driven supervision, and publishing of key reports on digitalisation.
Looking forward, the report notes EIOPA’s commitment to enhancing the Savings and Investment Union, which aims to create investment opportunities for EU citizens and in turn to allow business across Europe to grow.
EIOPA responds to the European Commission’s consultation on capital markets integration in the EU
On 19 June 2025, EIOPA responded to the European Commission’s consultation on capital markets integration in the EU, which is linked to the establishment of the savings and investments union strategy. This will achieve increased confidence amongst retail investors and reduce consumer anxiety. The regulation of cross border entities has been identified as a particular concern for EIOPA, which they highlight can be addressed by enhancing supervisory frameworks. Furthermore, EIOPA state that ensuring the equality of treatment of policyholders across the EU will be better achieved through product interventions, warnings, and technical assistance.
EIOPA publishes monthly technical RFR information
EIOPA published its monthly technical information on 23 June 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.
EIOPA notes positive early steps by insurers in addressing biodiversity risk but calls for stronger collaboration in key areas
On 30 June 2025, EIOPA published a report examining (re)insurers’ approach to biodiversity risk. EIOPA notes that, (re)insurers are beginning to measure biodiversity and nature-related risks and integrate them into their risk strategies. However, challenges remain, including limited availability of data, and the complexity of biodiversity (for example, due to the impact of climate change on biodiversity). EIOPA encourages greater collaboration among stakeholders and the identification of specific biodiversity related trends with the ultimate goal of supporting structured capacity building, enabling the insurance industry to better manage biodiversity risk.
EIOPA publishes research paper on insurers’ contrarian investments in mutual funds
On 25 June 2025, EIOPA issued a further paper assessing insurers’ role as ‘shock absorbers’ in the mutual funds sector following the introduction of its occasional research paper series in April 2025. As part of their research, EIOPA analysed investment patterns of insurers and found that insurers’ investments in mutual funds contributes to financial stability. This is because insurers typically purchase shares in funds when other investors are withdrawing. The study also notes that insurers’ ability to act in this capacity depends on their own financial strength, with better capitalised firms more likely to intervene. This means that insurers may be less likely to fulfil this role in times when they are less financially resilient (e.g. in times of severe systemic stress).
EIOPA publishes results of first coordinated mystery shopping exercise in EU insurance sector
On 17 June 2025, EIOPA published the results of its first EU-coordinated mystery shopping exercise which examined the sales process of insurance-based investment products (IBIPs) across 8 EU member states. The exercise’s aim was to compile insights on the sales process of IBIPs rather than assessing compliance with requirements.
The results highlighted that although customers are often provided relevant consumer information and key product details, there are still gaps in transparency, particularly around product costs. Most distributors (74%) asked about shoppers’ ability to hold onto products for the recommended holding period, including their investment horizon and overall financial situation. However, less than half of the interactions clearly explained the costs of these products. Also, whilst 84% of the products matched at least one consumer need, there was little correlation between thoroughness of the sales process and product suitability which indicates a need to simplify the sales process.
The European Commission is seeking feedback on a decision on the renewal of Brazil, Japan and Mexico provisional equivalence (Solvency II)
The European Commission is preparing to renew the provisional equivalence within the Solvency II regime for Brazil, Japan and Mexico pursuant to the European Commission draft act for feedback. This equivalence allows EU-headquartered insurance groups to take into account the calculation of capital requirements and available capital under the rules of non-EU jurisdictions, rather than calculating them on the basis of Solvency II. The renewal is based on Article 227 of the Solvency II Directive and is currently open for feedback until 3 July 2025, with the adoption of the delegated decision expected in the third quarter of 2025.
Insurance Europe has indicated that it would support the renewal of the provisional equivalence for Canada and Australia, where provisional equivalence is due to expire on 31 December 2025. This initiative aims to ensure continuity, stability and a more level playing field for EU insurers operating cross border, however if the provisional equivalence is not renewed, this would create a very significant competitive disadvantage for European insurers in provisionally equivalent markets.
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.