Insurance Europe has published a position paper today outlining industry recommendations in the implementation of the Insurance Recovery and Resolution Directive (IRRD).
The European Insurance and Occupational Pensions Authority (EIOPA) is currently developing technical standards and guidelines for the IRRD, which is expected to apply from 30 January 2027.
Insurance Europe remains committed to contributing to the discussions to ensure the Directive is ‘workable, efficient, and proportionate’ and reflects the realities of the insurance industry, while avoiding unnecessary complexity or burden.
In its paper, insurance Europe identifies several areas that it considers need further clarification and consideration:
- Implementation timing – the industry calls for the first pre-emptive recovery plans to be prepared no earlier than mid-2028.
- Unclear definitions – several key concepts, such as "compulsory minimum coverage," "material change," and "remedial actions," require clear definitions to ensure consistent application across the EU.
- Minimum market coverage requirements – Insurance Europe calls for a logical approach to meeting minimum market requirements, firstly recognising insurance group plans before requiring additional plans from smaller entities.
- Subsidiary company planning requirements – the industry stresses that subsidiary-level plans should only be required if issues cannot be addressed via the group plan.
- Financing arrangements – greater clarity is needed on the financing mechanisms for resolution, particularly for companies operating cross border under freedom of services (FoS) and freedom of establishment (FoE) rules.
- Critical functions – EIOPA’s guidelines on critical functions should allow for national discretion and consider the diversity of insurance markets across Europe.
- Other topics – further areas highlighted include confidentiality of plans, resolution authority responsibility and the special features of business and the differences between markets.