Simplification

Simplification for a more competitive
insurance sector

Simplification is not about deregulation. It is about smarter, clearer rules that keep safeguards
firm while cutting needless complexity.

READ OUR PAPER

Europe needs a regulatory framework that protects consumers and supports competitiveness. Today, insurers face layers of overlapping rules and reporting obligations that absorb resources that could otherwise strengthen protection, improve services and support long term investment.

Simplification does not lower standards. It increases impact. A clearer, more proportionate framework keeps safeguards in place while removing unnecessary complexity.

Why insurers are calling to simplify smartly

Europe’s rules have grown dense over time. This reduces efficiency and ultimately affects consumers. As highlighted in the report:

Frees resources for progress

Insurers spend time and money producing hundreds of pages of repetitive reports. Cutting duplication would release capacity for faster digital claims, climate-resilient products and green investment.

Protects people without waste

A proportionate framework preserves the strongest safeguards while avoiding rules that deliver little benefit.

Keeps cover affordable

Constant rule changes increase compliance costs and make planning difficult. More stability allows insurers to invest in innovation, infrastructure and the transition.

What needs to change

The simplification agenda should focus on practical steps that reduce overlap, streamline frameworks and improve proportionality across the sector. The paper identifies six areas where this has immediate impact.

1. Prudential, compliance and reporting

Insurers face dense layers of reporting and supervisory requirements across Solvency II, the Insurance Recovery and Resolution Directive (IRRD), anti-money laundering (AML) and international tax rules. Many of these obligations overlap or repeat information that supervisors already receive. Simplifying the structure, focusing on material risks and applying proportionality consistently would release significant resources without reducing safeguards.


What simplification delivers

  • Removal of duplicative requirements
  • Lower reporting pressure at critical times of the year
  • More consistent proportionality for undertakings and groups
  • More predictable implementation timelines

Key steps

  • Delete sustainability risk plans under Solvency II (Art. 44)
  • Abolish Q4 QRT reporting; streamline SFCR

    (short public section + quantitative annex)

  • Extend proportionality beyond SNCUs and

    ensure consistent application at group level (allow use of historical data or exclusion of exempted SNCUs)

  • Reconsider the need and design of regular EU-wide stress tests
  • Introduce “stop-the-clock” for IRRD
  • Reduce frequency of low-risk AML product reviews and delete excessive Know-Your-Customer (KYC) data points
  • Extend the CbCR Safe-Harbour to allow

    sufficient time to assess the efficiency of GloBE rules and design a permanent safe-harbour

2. Distribution and disclosures

Consumers face long, complex purchase journeys, often driven by overlapping disclosures and tests. The Retail Investment Strategy (RIS) debate provides a chance to simplify, reduce duplication and improve the clarity of information provided.


What simplification delivers

  • Clearer, more engaging disclosures
  • Faster, smoother purchase processes
  • Less administrative burden across distribution channels

Key steps

  • Keep Value for Money benchmarks for supervisors only, based on existing data and not published & avoid peer grouping by market participants
  • Ensure a smooth and lean purchasing

    process (e.g., do not add new questions to the suitability and appropriateness assessments)

  • Focus disclosures on what truly matters to consumers and make them more engaging

3. Sustainability

The sustainability framework already contains extensive reporting obligations under CSRD, ESRS, the EU Taxonomy, SFDR and Solvency II. The priority now is coherence, stability and alignment across these rules to avoid unnecessary burden and support the transition.

What simplification delivers

  • Clearer digital requirements
  • Lower compliance costs
  • Stronger support for innovation and resilience

Key steps

  • Apply 10% materiality threshold in EU Taxonomy; simplify templates
  • Align SFDR, CSRD, Taxonomy to avoid

    duplication

  • Keep ESRS assurance limited; Remove new

    sector-specific standards

  • Delete sustainability risk plans under

    Solvency II

4. Digital and innovation

Insurers operate under multiple digital frameworks, including AI, GDPR, DORA, the Cyber Resilience Act and cloud rules. These frameworks often overlap, leading to duplication, legal uncertainty and higher costs. The Digital Omnibus package is the opportunity to streamline.

What simplification delivers

  • Clearer digital requirements
  • Lower compliance costs
  • Stronger support for innovation and resilience

Key steps

  • Cut duplication between AI Act, GDPR, DORA, CRA
  • Allow reliance on EU-recognised cloud certifications and shared ESA audits
  • Streamline and harmonise cybersecurity reporting
  • Ensure a more proportional and efficient DORA application

5. Data protection

GDPR remains a cornerstone of privacy protection, but parts of the framework impose burdens that do not reflect risk. Greater clarity and proportionality would support innovation and improve consistency while keeping strong safeguards.

What simplification delivers

  • Clearer rules on international transfers
  • Practical tools for industry codes of conduct
  • Legal certainty for processing health data

Key steps

  • Clarify risk-based approach to data

    transfers; make monitoring body optional for codes of conduct

  • Introduce a clear legal basis for processing health data

6. Supervision and governance

Supervisory complexity and national divergence undermine consistency and predictability. A more coordinated approach would support trust, reduce unnecessary cost and strengthen the single market.

What simplification delivers

  • Greater legal certainty
  • Fewer hidden obligations
  • Less regulatory churn

Key steps

  • Prevent EIOPA Q&As from creating “hidden

    legislation”

  • Require quantitative impact assessments for

    all new measures

  • Extend review timelines in directives
  • Phase out disproportionate national templates

Search Simplification archive

Contacts

Carolien Afslag

Senior policy advisor, prudential regulation
+32 2 894 30 16