Insurance Europe has responded to a consultation by the European Insurance and Occupational Pensions Authority (EIOPA) on its proposed amendments to supervisory reporting and public disclosure documents.
While EIOPA’s proposals take into consideration a few of the many concerns that were raised in the past by the industry, EIOPA’s proposed changes are disproportionate and would lead to excessive new administrative burdens and costs for insurers (which would ultimately be passed on to customers).
This is because, while EIOPA has made some welcome changes, it has also introduced significant and mostly unnecessary changes to current quantitative reporting templates (QRTs), while at the same time introducing new QRTs. This would all place a significant extra administrative burden on insurers, without a clear benefit for supervisors.
It would also significantly increase costs for insurers, who would, for example, need to set aside major resources to implement, test and validate the required changes in their IT systems. EIOPA should, therefore, limit any changes to the reporting package to those that are absolutely necessary to fulfil its supervisory duties.
Moreover, the timeline proposed by EIOPA for these extensive changes is too short. The changes should be made as part of the wider review of Solvency II that is currently taking place, rather than through a piece meal approach that will lead to multiple changes being made within a short time frame, which would further exaggerate costs.