Insurance EuropeInsurance Europe
Position Paper
Response to EC digital finance strategy consultation

This is Insurance Europe's response to a consultation by the European Commission on its digital finance strategy.

EU rules for insurance should enable innovation and allow consumers, established companies and new market entrants to benefit from the opportunities that digitalisation can offer. However, this is currently not the case. For example, regulatory barriers exist to providing insurance to consumers online, such as requirements for documents to be provided on paper.

Policymakers should therefore review and adapt existing rules to ensure that they are innovation and digital friendly, technologically neutral and sufficiently future-proof to be fit for the digital age and encourage digital innovation.

Another key issue is the lack of a level playing field. New financial service providers entering the market often face less strict regulatory requirements than traditional financial services companies. It is therefore crucial to respect the principle of “same activities, same risks, same rules” and strive for a true level playing field.

At the same time, promoting a data-driven financial sector is an important and valuable aim. Enhancing legislation on access to, processing and sharing of data is important in order to promote innovation and competition. The insurance industry is therefore supportive of efforts to facilitate appropriate data sharing, in which the treatment of different players is based on a true level playing field.

Finally, a key challenge for insurers relates to the current lack of collaboration between competent authorities regarding innovation. As such, there is a need for all competent authorities to work more closely together to help further develop the digital single market for financial services.

Published 2 July 2020
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