Insurance Europe has submitted its response to the European Commission’s consultation on fair access to financial services for cancer survivors. The response reaffirms its support for fair access and calls for evidence-based measures that reflect national circumstances.
Insurance Europe supports prioritising the right to be forgotten (RTBF) for life insurance covering mortgages on primary residences and professional loans. This targeted approach can help cancer survivors access housing and credit, while allowing its impact to be assessed before considering other products.
National flexibility is central to the response. Member States should retain the freedom to choose legislation, self-regulation or other mechanisms suited to their markets.
Robust medical, scientific and actuarial evidence should underpin national frameworks and their review. Waiting periods and reference grids should reflect differences between cancer types, treatments and prognoses, without requiring every country to use both tools.
The response also calls for proportionate monitoring of access, affordability, product availability and effects on other policyholders. Relevant medical disclosure should support eligibility checks and monitoring. Once RTBF conditions are met, however, this information should not influence individual eligibility, pricing or contractual terms.
Monitoring should draw on national authorities, medical, scientific and actuarial experts, the insurance sector, including national insurance associations and reinsurers, and cancer patients’ organisations. Existing reporting arrangements should be used wherever possible to avoid unnecessary burdens.