KPMG updates
Advancing AI across insurance
AI is transforming the insurance industry by automating claims, assessing risk, personalising products, and fighting cybercrime. The KPMG report (authored by Frank Pfaffenzeller, Global Head of Insurance and Simona Scattaglia, Global Insurance Technology Lead) highlights that while insurance organisations are investing in AI, projects are slow to reach production. Balancing innovation with risk management is crucial. There is a need for a solid digital foundation, clean data, and upskilling employees to bridge the gap between AI and data. Successful organisations will be data-driven and people-led, leveraging AI to achieve their ambitions over the next three years.
CEO Outlook 2024 - Leadership perspectives on tech, people and change
The KPMG 2024 CEO Outlook report provides insights from over 1,300 global CEOs on key issues such as economic confidence, technology, talent, Environmental, Social, and Governance (“ESG”), and geopolitical concerns. Despite economic volatility, Chief Executive Officers (“CEOs”) remain optimistic and plan to increase their workforce, focusing on Artificial Intelligence (”AI”) and upskilling. Attracting and retaining talent is a top priority, with hybrid working patterns under discussion. ESG compliance and geopolitical risks are also significant concerns. Irish CEOs are particularly ambitious about leveraging AI and remain confident in economic growth.
CEO Outlook 2024 – Northern Ireland - Leadership perspectives on tech, people and change
CEOs in Northern Ireland are optimistic about the future, with 93% confident in the three-year economic outlook and 90% planning to increase headcount. The KPMG 2024 CEO Outlook report highlights that Northern Irish CEOs are particularly ambitious about leveraging AI and related technologies. However, they face challenges in attracting the right talent and capabilities. The report also notes ongoing debates about hybrid working, with many leaders expecting a return to pre-pandemic working patterns within three years. Additionally, there are significant concerns about meeting ESG commitments and ensuring compliance with new reporting standards.
Tech-savvy CEO - The CEO view on Artificial Intelligence and cyber risk
CEOs are prioritising generative AI to drive growth and innovation, despite not being digital natives. The KPMG 2024 CEO Outlook report highlights that 67% of CEOs in the Republic of Ireland (“ROI”) and 63% in Northern Ireland (“NI”) see AI as a top priority, surpassing economic and geopolitical concerns. Ethical issues and lack of regulation are significant challenges, with 87% of ROI and 77% of NI CEOs expressing concerns about AI ethics. The European Union AI Act is seen as a tool to address these challenges, underscoring the importance of robust data and technology foundations.
Data Centres 2030 - Get informed with our series on disruption as an opportunity in the digital infrastructure ecosystem
Meeting the demands of AI data centres is a significant challenge for the industry. Intense competition, energy constraints, and the need for advanced cooling systems weigh heavily on data centre operators. KPMG (led by Christopher Brown (Partner, Head of Strategy)) emphasises the importance of innovative solutions, such as extending server lifespans, pursuing renewable energy, and managing supply chain bottlenecks. The report underscores the critical role of robust infrastructure in supporting the exponential growth of AI applications.
Components of a modern, effective board - Effective board composition is a significant challenge for ambitious organisations
Ensuring the most effective board composition is a significant challenge for ambitious organisations. Intense competition, volatility, reputation, and the risk of unforeseen events weigh heavily on the minds of board chairs and decision makers. KPMG (led by Ryan McCarthy (Audit Partner and Board Leadership Centre Lead) emphasises the importance of having a board with diverse skills and perspectives to avoid groupthink. He highlights the need for board members to focus on adding value to the current organisation and stresses the importance of curiosity and the ability to ask insightful questions to drive valuable discussions and decisions.
Internal Audit: Quality Assurance and Improvement Programme - What are the key concerns in audit quality?
Internal Audit (“IA”) functions serve as the last line of defense to ensure organisational elements meet rising expectations. High-quality audits are crucial for maintaining the IA function's relevance to business needs. The Institute of Internal Auditors (IIA) International Standards outline quality assurance requirements for IA functions. Establishing a quality assurance function to continually assess IA effectiveness has become standard practice for large audit teams across all sectors. KPMG (led by Patrick Farrell (Risk Consulting Partner) and the Internal Audit team) delve into this topic further.
Central Bank Updates
Central Bank: Speech
The Central Bank of Ireland (“the Central Bank”) published a speech given by the Deputy Governor, Sharon Donnery at the Health Insurance Authority Conference entitled ‘Best Interests – delivering for consumers in a complex world’. The Deputy Governor also noted following the consultation phase, the Central Bank will be publishing a revised Consumer Protection Code along with a feedback statement in 2025. In addition, a new supervisory approach is being undertaken that will be implemented from January 2025 in which an integrated risk-based approach will involve integrated teams working together to supervise all areas of the mandate (i.e. Conduct, Financial Resilience & Governance).
Central Bank: Insurance Newsletter September 2024
The Central Bank published its September edition of the Insurance Newsletter. The Central Bank provides examples of “stronger assessments” which it observed as part of its Thematic Review of Climate Change Risk Materiality Assessments; encourages firms to continue to build on their analysis of climate change risks; sets out a number of positive practices, practices requiring improvement and regulatory expectations relating to the administration of unclaimed life assurance policies; and advises firms to continue to closely monitor the impact of Personal Injury Guidelines and Claims Inflation (H2 2023). The Central Bank also lists out a number of regulatory expectations on the use of big data and related technologies.
European Insurance and Occupational Pensions Authority Updates
EIOPA: Collaboration of Insurance Supervisory Authorities
The European Insurance and Occupational Pensions Authority (“EIOPA”) has published a report following up on its December 2020 peer review of its Decision on the collaboration of insurance supervisory authorities. The follow-up report describes the extent to which National Competent Authorities (“NCAs”) have implemented the recommended actions addressed to them from the previous report 2020 report.
EIOPA: Leveraging insurance to shore up Europe’s climate resilience
EIOPA has welcomed the new report published by the Climate Resilience Dialogue in July 2024. The Climate Resilience Dialogue is convened by the European Commission and includes 17 organisations to represent a full range of stakeholders from various parts of the economy (e.g. insurers, reinsurers, risk managers, public authorities and regions, and representatives of consumers and the real economy). The report includes insights from the various stakeholders and aligns closely with EIOPA’s own sustainable finance priorities.4.
EIOPA: PEPP Reforms
EIOPA has published a staff paper on the future of the pan-European personal pension product (“PEPP”). In the paper, EIOPA analyses the reasons why the PEPP has had limited success to date and highlights issues including the inherent expenses in offering PEPPs, the limited targeted market for these products, low participation and awareness by consumers concerning pensions, and the behaviour of some Member States in making it difficult or impossible to sell PEPPs in their jurisdictions.
EIOPA: Speech
EIOPA have published a speech given by the EIOPA Chair Petra Hielkma entitled “The role of reinsurance in promoting healthy markets”. In the speech, Ms Hielkma addresses several key issues: the European Commission (“EC”) is focusing on competitiveness in the reinsurance sector and the EU's reliance on third-country reinsurance; the green agenda remains a priority, with a need for advancing transition plans; the Solvency II Directive provides a solid framework, with increased supervisory focus on conduct and emerging issues; complex reinsurance structures and mass-lapse reinsurance arrangements are under scrutiny to ensure genuine risk transfer and asset-intensive reinsurance contracts, which introduce counterparty risk, are also being closely monitored. EIOPA plans to consult on guidance for national supervisors by the end of 2024.
EIOPA: Monthly update of the symmetric adjustment of the equity capital charge for Solvency II – end-August 2024
On 4 September, EIOPA published its monthly technical information for Solvency II relevant risk-free interest rate term structures with reference to the end of August 2024.
EIOPA: Monthly technical information for Solvency II relevant risk-free interest rate term structures – end-August 2024
On 4 September, EIOPA published its most recent technical information on the symmetric adjustment of the equity capital charge for Solvency II with reference to the end of August 2024.
EIOPA: Updated technical information for calculating risk-free interest rate term structure RA
From January 1 2025, EIOPA will stop publishing technical information for 11 non-EEA currencies, including the Brazilian real, Indian rupee, and South African rand, among others. These currencies are not considered material for the EU insurance sector. The updated technical risk-free interest rate documentation will take effect on the same date with the first calculations based on it occurring at the end of January 2025. Until then, the current version of the documentation remains in use.
UK Updates
FCA: General insurance and pure protection product governance thematic review
On 27 August, the Financial Conduct Authority (“FCA”) published a thematic review which details how firms should manufacture and distribute products that deliver fair value to customers.
FCA: General insurance value measures data 2023
On 21 August, the FCA published their value measures data. This is the second full year of general insurance value measures data covers January to December 2023.
FCA: Market study into the Distribution of Protection Products to Retail Customers
On 28 August, the FCA published a proposed Terms of Reference for a market study into the distribution of pure protection products to retail consumers.
FCA: Assessing firms’ compliance with ‘back end’ crypto financial promotions rules
On 7 August, the FCA published their findings and identified good and poor practice for the wider sector to consider and make any necessary changes to their own practices.
FCA: The Value for Money Framework
On 8 August, the FCA published their guidance for a new value for money (VFM) framework for savers invested in default arrangements of workplace defined contribution (DC) pension schemes.
PRA: PRA Regulatory Digest - July 2024
On 1 August, the Prudential Regulation Authority (PRA) published its regulatory digest which is for people working in the UK financial services industry and highlights key regulatory news and publications delivered for the month.
PRA: Shock transmission, global supply chains, and development
On 9 August, the PRA published a working paper which sets out research by PRA staff, with the aim of encouraging comments and debate. This paper discusses a DSGE model in which commercial banks interact with the central bank through the reserves market, with each other through reserves and interbank markets, and with the real economy through retail loan and deposit markets.
Other European and International Supervisory Authority Updates
IAIS: Part Four: Climate Risk
The International Association of Insurance Supervisors (IAIS) has extended the deadline for responses to its fourth consultation on climate risk supervisory guidance to 28 October 2024. The IAIS has extended the deadline given the extensive stakeholder interest in the consultation. The consultation is the last of a series of four consultations on proposed changes to guidance relating to various insurance core principles (“ICPs”) and on new supporting material to better incorporate climate-related risk as part of effective supervisory practice.
IAIS: Newsletter July/August
On 29 August, the IAIS published their newsletter for July/August. The newsletter covers various in focus and topical areas for the Insurance sector such as AI, Climate Change and Fintech whilst highlighting past and upcoming events within the IAIS.
IE: Making the Retail Investment Strategy work for insurance and consumers.
Insurance Europe (“IE”) published an information document detailing the importance of the Retail Investment Strategy (“RIS”) in the context of insurance-based investment products (“IBIPs”). It highlights how IBIPs provide unique benefits, such as risk coverage and financial guarantees, which are not adequately considered in the current RIS framework. Insurance Europe calls for a more balanced approach that prioritises the qualitative aspects of insurance products, supports product diversity and ensures that distribution channels, including smaller ones, are not disadvantaged. It also emphasises the need to reduce information overload for consumers and to focus on essential information that aids their investment decisions.
IE: Response to the EC targeted consultation on AI in the financial sector
On 13 September, IE published its response to the EC targeted consultation on AI in the financial sector. IE highlights the potential benefits of AI, such as improved efficiency and customer service, but also warns of risks like market concentration and dependency on a few AI providers. The response emphasises the need for balanced regulation to foster competition, protect data privacy, and ensure that AI integration does not increase the compliance burden. It also suggests promoting data sharing under strict conditions to enhance AI development while safeguarding sensitive information.
EIOPA Q&A Updates
Please see below for EIOPA’s response to recent queries which have been raised by the public for further clarification on the Solvency II requirements. The Solvency II requirements may change or become more prescriptive over time.
29 August 2024: TPs
EIOPA clarified in Q&A (#2691) that for personal accident riders attached to life insurance contracts, claims reserves be valued using non-life techniques and stressed under the health NSLT module, and premium reserves are valued using life techniques under the SLT Health or Life UW modules if it is possible to unbundle the contract.
20 August 2024: S.04.04
EIOPA clarified in Q&A (#3095) that there is an error in the XBRL taxonomy. The constraints (usable/non-usable) of the hierarchy members that can be found in the dictionary part are not reflected in the table definition layer.
20 August 2024: S.37.02
EIOPA clarified in Q&A (#3095) that there is an error in the XBRL taxonomy. The constraints (usable/non-usable) of the hierarchy members that can be found in the dictionary part are not reflected in the table definition layer.
20 August 2024: SCR
EIOPA clarified in Q&A (#3091) that undertakings should derive events which are consistent with their risk profile and select the event which results in a highest catastrophe charge after the application of the risk mitigation techniques.
06 August 2024: TPs
EIOPA clarified in Q&A (#3082) that taxes or levies levied as a percentage of an insurer's operating income, which are not charged to policyholders and which are not required to settle the insurance or reinsurance obligations, do not constitute taxation payments and should therefore not be included in the cash flow projection used in the calculation of the best estimate
19 August 2024: S.09.01
EIOPA clarified in Q&A (#3082) that taxes or levies levied as a percentage of an insurer's operating income, which are not charged to policyholders and which are not required to settle the insurance or reinsurance obligations, do not constitute taxation payments and should therefore not be included in the cash flow projection used in the calculation of the best estimate.
20 August 2024: S.36.01
EIOPA clarified in Q&A (#3047) that for transactions between entities of the same group, i.e. between the Investor/Lender (the entity that is buying the equity or lending to a related undertaking within the group) and the Issuer/borrower, the group is expected to capture the payments made in relation to this intra group transaction.
19 August 2024: S.06.02
EIOPA clarified in Q&A (#2975) that:
- In case the instruments are government bonds which are denominated in the domestic currency, they should be reported as category 18. Covered bonds and treasury bonds which are issued by central governments and central banks and bonds that are fully, unconditionally and irrevocably guaranteed by the European Central Bank, Member States’ central government and central banks in case of different currency than the central government are to be reported with category 15 and 16.
- Bonds that are fully, unconditionally, and irrevocably guaranteed by central banks outside of EU/EEA should also be reported with CIC code 17.
- Instruments that are fully, unconditionally, and irrevocably guaranteed by Member States' central governments and central banks which are denominated in a currency which is different from the domestic currency of the central bank or central government should be reported with CIC code 18.
Instruments that are fully, unconditionally, and irrevocably guaranteed by non-EU/EEA central governments are classified similarly as their EU/EEA counterparts should be categorised with CIC code 2.
19 August 2024: S.23.01
EIOPA clarified in Q&A (#2951) that row R0790 in S.23.01 should also be reported gross of reinsurance and taxes, thus R0790 is still the sum of R0770 and R0780 (there is an active validation checking that expression, operating since at least 2.6.0). This will be clarified in the next ITS amendments.
Further information
For more on any of the items above, or any Insurance-related queries, contact Brian Morrissey, Head of Insurance. We'd be delighted to hear from you.