Domestic

CBI publishes Investment Firm and Intermediary Newsletter

On 27 November 2025, the Central Bank of Ireland (CBI) published its Investment Firm and Intermediary Newsletter for November 2025. The edition covers a range of topics relevant to insurance intermediaries including:

• findings from the CBI’s ‘Thematic Review of Limited Vs Fair Analysis of the Market’
• updates on implementation of the individual accountability framework and the Consumer Protection Code 2025
• administrative changes to the approval process for sole traders transitioning to single director companies and applications for authorisation by intermediaries using the ‘A Form’
• key supervisory activities and publications issued by the CBI and the European Insurance and Occupational Pensions Authority (EIOPA) in the latter part of 2025

CBI releases Insurance Corporation Statistics

On 28 November 2025, the CBI released its Insurance Corporation statistics for Q3 2025.

Key points to note include:

• A €26bn increase in total assets of Irish insurance corporations on the same period last year. Total assets now stand and €487bn, such growth being attributable to investment fund shares/units holdings and direct equity holdings.
• Insurance corporations’ liabilities grew on a quarterly basis in Q3 2025, which reflected a €14bn increase in unit linked life insurance technical reserves (ITRs). Meanwhile, non-unit linked life ITRs remained stable in Q3 2025, while non-life ITRs grew by €1.4bn.
• Reinsurance reserves comprise the largest sub-category of non-life ITR liabilities at €35.3bn; larger than all other sub-categories of liabilities combined.

European

EIOPA supports the NGFS Declaration on the Economic Cost of Climate Inaction

On 5 November 2025, at the 2025 Climate Change Conference (COP30), EIOPA announced its support for the Network for Greening the Financial System’s (NGFS) Declaration on the Economic Cost of Climate Inaction. NGFS is a global coalition of central banks, financial regulators and observers, aimed at supporting the transition to a low carbon economy.

Among other things, the Declaration urges financial institutions to embed climate and nature-related risks in their strategic planning and operations. It warns that postponing climate measures could reduce transition effectiveness by half, with associated costs also increasing if action is delayed. The Declaration also emphasises the risks posed by climate-related shocks, which may lead to macro-financial instability while disproportionately harming vulnerable economies. Noting the role insurers can play in the transition to a low-carbon economy, Chair of EIOPA, Petra Hielkema, also observed that the insurance sector alone cannot drive change, and that cross-sectoral support is imperative to any successful transition.

EIOPA’s draft RTS on new macroprudential requirements

On 17 November 2025, EIOPA submitted two sets of draft regulatory technical standards (RTS) to the European Commission (the Commission) which aim to implement new macroprudential tools designed to strengthen insurers’ resilience. The RTS focus on two key areas:

liquidity risk management plans (LRMPs)

under this proposal:

• insurers and groups will have to maintain LRMPs to ensure appropriate liquidity
• entities with over €20bn in assets will have to prepare medium and long-term liquidity analyses (as well as conducting shorter term assessments)
• entities will be expected to update their LRMPs annually and “without delay” following any significant changes to risk profile or to relevant external factors

macroprudential risk analyses

if these proposals are implemented:

• some reinsurers will be required to integrate macroprudential analyses into their ORSA and their application of the prudent person principle
• quantitative thresholds (€20bn assets) and risk profile will determine the selection criteria for macroprudential analyses

The Commission will now review EIOPA’s proposals and decide on whether to adopt them within three months.

Commission Implementing Regulation regarding the calculation of technical provisions and basic own funds for reporting from 30 September 2025 until 30 December 2025

On 18 November 2025, a Commission Implementing Regulation (CIR) was published in relation to Solvency II. The CIR noted that insurance and reinsurance undertakings must use the technical information provided by EIOPA when calculating technical provisions, matching adjustment and volatility adjustment to ensure uniformity across all EU insurers for prudential reporting.

The CIR noted insurers should use technical information based on market data from the end of the previous month and that given the need for the immediate availability of the technical information, it was important that the Regulation entered into force as a matter of urgency. The CIR is in force as of 30 September 2025.

Proposal for regulation on sustainability-related disclosures in the financial services sector

On 20 November 2025, the Commission adopted a proposal for a regulation amending Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR), Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs) and repealing Commission Delegated Regulation (EU) 2022/1288 on sustainability-related disclosure in the SFDR.

The proposal highlighted the complexity, difficulty in implementation, and ineffectiveness of the SFDR and introduces a major simplification of disclosure requirements. Proposed simplifications include the establishment of a three-tier classification system for ESG-related financial products, reflecting broad stakeholder input and current market practices. The proposal also includes targeted amendments to the PRIIPs Regulation ((EU) 1286/2014) and repeals the regulation currently implementing the SFDR (Regulation (EU) 2022/1288).

The proposed regulation will now be considered by the European Parliament and Council. If adopted, the regulation will enter into force 20 days after its publication in the Official Journal of the European Union and will apply 18 months from that time.

Date published: 22 December 2025

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.